ABDUL KADIR IBRAHIM ANTULE,MUMBAI vs. ITO, WARD 1, PANVEL, PANVEL

ITA 406/PUN/2026Status: DisposedITAT Pune21 September 2026AY 2013-1410 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were void ab initio because the mandatory notice under Section 148 was never served on the assessee. Consequently, the reasons recorded for reopening were also found to be insufficient.

What were the facts?

The assessee's appeal challenges the validity of reassessment proceedings initiated under Section 147 and the subsequent addition of cash deposits as unexplained money. A key contention is that the notice under Section 148 was never served on the assessee.

What were the issues?

Whether the reassessment proceedings are valid when the mandatory notice under Section 148 was not served on the assessee, and whether the reasons recorded for reopening were sufficient to establish escapement of income.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144,Section 69A,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “SMC”, PUNE

Before: SHRI Dr. DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Shri Subodh Ratnaparkhi
For Respondent: Shri Prashant Barate

PER Dr. DIPAK P. RIPOTE, A.M : This is an appeal filed by assessee against the order of Commissioner of Income Tax (Appeals) u/s 250 of the Income Tax Act 1961, for AY 2013-14 dated 24/11/2025, emanating from Assessment Order u/s 147 r.w.s. 144 of the Income Tax Act dated 10/09/2021. 2. The Assessee has raised following grounds of appeals: “On the facts and in law,

1.

The Hon CIT (A) erred in upholding the validity of assessment framed on 10.09.2021 u/s 147 r.w.s 144 of the I.T Act, 1961 without first serving on the appellant, a valid notice u/s 148 of the I.T. Act, 1961 and therefore the order of assessment is bad in law and is required to be quashed on that account.

2.

The Hon CIT (A

The order continues below.

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