RAYAPU REDDY YARAVA vs. ITO, WARD -1, WARANGAL

Parties Involved

Facts Summary

The assessee, RAYAPU REDDY YARAVA, has appealed against the order of the learned CIT(A)-National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2015-2016. The assessee has raised several grounds of appeal, primarily challenging the validity of reassessment proceedings initiated by the issuance of notice under section 148 dated 22-04-2022. The assessee argues that the reassessment proceedings are barred by limitation under section 149(1)(a) of the Act, as the escaped income assessed is below Rs. 50,00,000, and the permissible period of three years expired on 31-03-2019. Additionally, the assessee contends that the reassessment proceedings are void ab initio due to the jurisdictional Assessing Officer issuing the notices under sections 148A(b), 148A(d), and 148 contrary to section 151A and the Faceless Reassessment Scheme, 2022.…

Legal Issues

• 1. Whether the reassessment proceedings initiated by issuance of notice under section 148 dated 22-04-2022 are barred by limitation?
• 2. Whether the notice issued by the Assessing Officer u/sec.148 of the Act on 22.04.2022 is valid?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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