The Central Board of Direct Taxes flagged three large cash deposits—₹13 lakh, ₹60 lakh, and ₹50,000+—in his savings account during the 2015‑16 assessment year, triggering a reassessment under the risk‑management strategy.
On March 26, 2022, the Income Tax Department issued a Section 148A(b) notice, but the teacher did not reply. A month later, an AO sent a Section 148(d) order, opening a formal reassessment, and a 30‑day Section 148 notice was dispatched on April 26, 2022.
He filed a paper ITR within the deadline, but the filing was not e‑verified, rendering it invalid. Subsequent show‑cause notices under Section 142(1) received only partial compliance, and the AO eventually assessed ₹48.85 lakh income on February 29, 2024.
IHe appealed to the CIT (A), which dismissed the case, forcing him to the ITAT Bangalore. The SMC Bench heard the appeal on April 15, 2026, and on July 10, 2026, quashed the reassessment order.
ITAT held that the Section 148 notice was issued 26 days after the six‑year limitation for the 2015‑16 year had lapsed, citing the Rajeev Bansal Supreme Court precedent and Karnataka High Court decisions. The delay invalidated the reassessment, clearing the teacher’s record.
Now, the retired teacher, who has spent decades shaping young minds in Mysore, will finally see his tax file settled, a relief that comes after years of paperwork and uncertainty.