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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
Ravish Sood, J, Madhusudan Sawdia, Accountant Member
Ramesh Kumar Pandey – Appellant
Versus
Income Tax Officer, Nizamabad. Ward-1 – Respondent
| Table of Content |
|---|
| 1. assessee's grounds challenging procedural lapses and notices (Para 8) |
| 2. arguments on section 148 notice beyond limitation (Para 9 , 10 , 11 , 12) |
| 3. first proviso to section 149 bars post-2022 notices (Para 13 , 14 , 15 , 16) |
| 4. assessment quashed for lack of jurisdiction (Para 17 , 18 , 19) |
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 11/09/2025, 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 24/02/2023 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 Ld. CIT(A) erred in facts and law while passing the order.
2. The Ld. CIT(A) has not considered that the learned AO as per his/her convenience very calculatedly assumed that the assessee" "chose to remain silent on the proposed action" and furnished no reply, despite "sufficient opportunity provided". It is to bring to your kind notice that the asses
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