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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Manjunatha G., Accountant Member, Ravish Sood, Judicial Member
Sudha Doshi – Appellant
Versus
Income Tax Officer – Respondent
| Table of Content |
|---|
| 1. assessee's grounds challenging reassessment jurisdiction and additions. (Para 9) |
| 2. factual background of return, bogus f&o trading, and reassessment proceedings. (Para 10) |
| 3. assessee argues s.148 notice barred by s.149 limitation. (Para 11 , 12 , 13) |
| 4. revenue defends via lower authority orders. (Para 14) |
| 5. first proviso to s.149 bars s.148 notice beyond pre-2021 limit. (Para 15 , 16 , 17 , 18) |
| 6. reassessment quashed for lack of jurisdiction; appeal allowed. (Para 19 , 20 , 21) |
आदेश/ORDER
PER. RAVISH SOOD, J.M:
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 26/08/2025, 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 24/05/2023 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 order of the Ld. CIT(A) is bad in both law and on facts of the case.
2. On the facts and circumstances of the case, the order u/s 148A(d) dated 30.07.2022 and noti
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