148. In Pr. CIT v. NRA Iron & Steel (P) Ltd.

11 SCC 312Reported decision2020#9517 most cited
11

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2026 to 2026.

Sections most often in play

Section 115BBESection 115JBSection 132(1)Section 132(4)Section 142(1)Section 143(1)Section 143(2)Section 143(3)

Issues it is cited on

section 142(3)section 89section 147ofsection 142(2)section 69daudi alteram partemsection 149(1)(b)statement under section 132(4)section 132(4a)section 34section 292cpenny stock

Judgments citing 148. In Pr. CIT v. NRA Iron & Steel (P) Ltd.

M/S. SHAKAMBHARI ISPAT & POWER LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

ITA 931/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-2020
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1591/KOL/2025[2021-22]Status: DisposedITAT Kolkata02 Jan 2026AY 2021-22
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1561/KOL/2025[2020-21]Status: DisposedITAT Kolkata02 Jan 2026AY 2020-21
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1560/KOL/2025[2019-20]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-20
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

D.C.I.T., CC - 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1541/KOL/2025[2018-19]Status: DisposedITAT Kolkata02 Jan 2026AY 2018-19
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1515/KOL/2025[2017-18]Status: DisposedITAT Kolkata02 Jan 2026AY 2017-18
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3.1, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1436/KOL/2025[2016-17]Status: DisposedITAT Kolkata02 Jan 2026AY 2016-17
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

ITA 1198/KOL/2025[2021-2022]Status: DisposedITAT Kolkata02 Jan 2026AY 2021-2022
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), KOLKATA

ITA 1196/KOL/2025[2018-2019]Status: DisposedITAT Kolkata02 Jan 2026AY 2018-2019
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

M/S. SHAKAMBHARI ISPAT & POWER LTD.,KOLKATA vs. DCIT, CC - 3(3),, KOLKATA

ITA 1195/KOL/2025[2017-2018]Status: DisposedITAT Kolkata02 Jan 2026AY 2017-2018
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

M/S. SHAKAMBHARI ISPAT & POWER LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

ITA 1194/KOL/2025[2016-2017]Status: DisposedITAT Kolkata02 Jan 2026AY 2016-2017
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

148. In Pr. CIT v. NRA Iron & Steel (P) Ltd. (11 SCC 312) — Cited in 11 Judgments | BharatTax