Narendrasinh Chandansinh Solanki vs ITO, Ward-3(3)(2), Ahmedabad

Parties Involved

Facts Summary

The present appeal was preferred by the Assessee against the Order, dated 27/05/2025, passed by the National Faceless Appeal Centre (NFAC), Delhi whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 25/05/2023, passed under Section 147 read with Section 144 of the Income Act, 1961 for the Assessment Year 2017-2018. The Assessee contended that the reassessment proceedings were barred by limitation as the notice under Section 148 was issued beyond the period of Limitation Time prescribed in Section 149 and without following the procedure as prescribed in Section 148A. The Assessee relied on the judgment of the Hon’ble Supreme Court in the case of UOI & Ors Vs Rajeev Bansal (2024) 469 ITR 46 (SC). The Departmental Representative opposed the submission and supported the order passed by the Assessing Officer.…

Legal Issues

• 1. Whether the notice issued under Section 148 of the Act is barred by limitation?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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