Rahul Purswani Vs ITO (ITAT Pune)
The ITAT Pune held that the reassessment proceedings for AY 2015–16 were invalid as the notice issued under Section 148 dated 12.04.2022 was time-barred. Relying on judicial precedents, including the Supreme Court ruling that all notices issued on or after 01.04.2021 for AY 2015–16 must be dropped, the Tribunal quashed the notice and declared the consequent assessment order void ab initio. Additionally, on merits, the Tribunal found that the addition of ₹12,75,000 was unsustainable since the payments for the immovable property were made in FY 2013–14 (AY 2014–15), even though registration occurred in AY 2015–16. The Assessing Officer failed to verify basic facts and acted mechanically without application of mind. The Tribunal emphasized that such non-verification vitiates jurisdiction. Accordingly, the reassessment and addition were set aside, and the assessee’s appeal was allowed.
Assessee Represented by: CA Milind Wadhwani
FULL TEXT OF THE ORDER OF ITAT PUNE
This is an appeal filed by the Assessee against the Order u/s 250 of the Income Tax Act 1961 for AY 2015-16 dated 23/07/2025 emanating from the Assessment Order dated 26/03/2024 passed u/s 147 rws 144B of the Income Tax Act 1961.
Findings and Analysis :
2. We have heard both the parties and perused the records. Ld.AR has filed paper book
