2025 (10) TMI 1307

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....JESH KUMAR, AM: This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 06.05.2025 for the AY 2015-16. "That your assessee craves to plead an additional ground with the leave of this Tribunal under Rule 11 of the Income Tax (Appellate Tribunal) Rules, 1963 and ratio laid down by the ....

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....(SC), dated 03.10.2024. 03. The facts in brief are that the case of the assessee was reopened upon credible information regarding suspicious transactions in the bank account of the assessee maintained with ICICI bank Ltd. bearing A/c No.000605026646, was received through the Insight Portal. Upon considering the submission of assessee during the course of proceedings u/s 148A of the Income-tax A....

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....IT(A). 04. The Ld. Counsel vehemently submitted before us that the notice issued u/s. 148 of the Act is barred by limitation as benefit of TOLA is not available to the assessment year 2015-16. The assessee relied on in defense of his arguments on the decision of Hon'ble Apex Court in the case of Rajeev Bansal (Civil Appeal No.8629 of 2024, reported in 167 taxmann.com 70 (SC) pronounced on 03.10....

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....ower Ltd Vs CBDT (2025) 174 taxmann.com 144(SC) and therefore, prayed that the assessment framed may kindly be quashed. 05. After hearing the rival contentions and perusing the material available on record, we find that undisputedly, the notice u/s. 148 of the Act was issued on 31.07.2022 which falls beyond the period of limitation as the relaxation granted by TOLA w.e.f. 01.04.2021 to 30.06.20....