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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Pawan Singh, Judicial Member, Girish Agrawal, Accountant Member
DEVANAND AMARNATH PARKAR JOGESHWARI EAST MUMBAI – Appellant
Versus
INCOME TAX OFFICER 41(4)(1) KAUTILYA BHAWAN BKC BANDRA EAST – Respondent
| Table of Content |
|---|
| 1. assessee challenges reassessment notice validity. (Para 1 , 2 , 3) |
| 2. notice u/s 148 beyond 3-year limitation. (Para 4) |
| 3. notice quashed as time-barred under new regime. (Para 5) |
| 4. appeal allowed; reassessment proceedings quashed. (Para 6) |
ORDER
PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:
This appeal filed by the assessee is against the order of ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi, vide order no. ITBA/NFAC/S/250/2025-26/1080924932(1), dated 19.09.2025, passed against the assessment order by National Faceless Assessment Center, New Delhi, u/s. 147 r.w.s 144B of the Income-tax Act (hereinafter referred to as the “Act”), dated 22.05.2023 for Assessment Year 2017-18.
2. Grounds taken by the assessee are reproduced as under:
1. On the facts and circumstances of the case and law, the Ld CIT(A) grossly erred & failed to appreciate that the reopening of assessment vide notice u/s 148 of the Act dated 30/07/2022 i.e After expiry of three years from the end of the assessment year 2017-18 without appreciating that notice under section 148 can be issued beyond 3 years only if income escapement is above 50 lacs, in fact of present case the impugned notice issued fo
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