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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
RAVISH SOOD, Judicial Member, MADHUSUDAN SAWDIA, Accountant Member
VIJAYA MALISETTY – Appellant
Versus
Income Tax Officer, Khammam. Ward-1 – Respondent
| Table of Content |
|---|
| 1. assessee challenges addition of firm turnover as personal income (Para 8) |
| 2. assessee contests validity of section 148 notice jurisdiction (Para 9) |
| 3. post-2021 reassessment requires specified authority approval (Para 10 , 11) |
| 4. beyond 3 years needs pcit approval; proviso not retrospective (Para 12 , 13 , 14 , 15) |
| 5. quash assessment for invalid jurisdictional approval (Para 16 , 17 , 18) |
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 19/05/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 13/02/2024 for the Assessment Year (AY) 2018-19. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:
1. “The learned Commissioner ought to have appreciated that the assessee along with her reply denying that deposits in the Bank, submitted an Affidavit confirming the facts stated in the letter, denying the transactions as her business transactions, therefore,
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