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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Ravish Sood, Judicial Member, Madhusudan Sawdia, Accountant Member
Ramesh Babu Bejjala – Appellant
Versus
Income Tax Officer, Kothagudem. Ward-1 – Respondent
| Table of Content |
|---|
| 1. reassessment initiated due to cash deposits without return filing. (Para 7) |
| 2. section 148 notice time-barred beyond 31/03/2022 for ay 2015-16. (Para 8) |
| 3. first proviso to section 149 bars notices beyond old regime time limit. (Para 9 , 10 , 11 , 12 , 13) |
| 4. assessment quashed for lack of jurisdiction; other grounds left open. (Para 14 , 15 , 16) |
ORDER
PER RAVISH SOOD, JM:
The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 11/04/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 21/12/2023 for the Assessment Year (AY) 2015-16. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:
“1. The learned CIT(A) erred in upholding the Section 348 notice, which is unequivocally time-barred under Section 149(1)(b) of the Act. This section mandates that for reassessments Initiated beyond three years from the relevant assessment year, the escaped Income must exceed Rs. 50 laiths. Despite an initial al
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