INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

ITA 824/BANG/2025Status: DisposedITAT Bangalore24 November 2025AY 2016-17Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)19 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were bad in law and liable to be quashed because a notice under section 143(2) was not issued, which is mandatory even when a return is filed in response to a section 148 notice. The assessment order passed under section 144 r.w.s. 147 was deemed null and void.

What were the facts?

The assessee company's assessment was framed under section 144 r.w.s. 147 of the Act without issuing a notice under section 143(2). The Assessing Officer (AO) had initiated reassessment proceedings after a survey revealed potential inflation of expenses.

What were the issues?

Whether reassessment proceedings under section 147 are vitiated if a notice under section 143(2) is not issued, despite a return being filed in response to a section 148 notice.

Which sections of the Income-tax Act were involved?

Section 144,Section 147,Section 148,Section 143(2)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(10)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, “A’’BENCH: BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

Hearing: 03.09.2025Pronounced: 24.11.2025

PER KESHAV DUBEY, JUDICIAL MEMBER:

These appeals at the instance of the assessee are directed against the consolidated order of the ld. CIT(A)-11, Bengaluru, dated 10.02.2025 vide DIN : ITBA/APL/M/250/2024- 25/1073061567(1) for the AY 2015-16; vide DIN: ITBA/APL/M/250/2024-25/1073061747(1) for the AY 2016-17 and vide DIN : ITBA/APL/M/250/2024-25/1073061874(1) for the AY 2017-18 passed u/s 250 of the Income Tax Act, 1961 (in short “The Act”). Since the legal issues involved & the grounds taken in all these three appeals of the same assessee are common, these are clubbed together, heard together an

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →