How many judgments cite Suman Jeet Agarwal v. ITO?

85 judgments on BharatTax cite Suman Jeet Agarwal v. ITO (449 ITR 517), spanning 2023 to 2026.

Which sections of the Income Tax Act does Suman Jeet Agarwal v. ITO come up under?

It is most often cited in judgments turning on Section 1961, Section 147, Section 148, Section 148A, Section 143(3), Section 149.

Suman Jeet Agarwal v. ITO

449 ITR 517High Court2022#1347 most cited

What is Suman Jeet Agarwal v. ITO authority for?

A notice under Section 148 or 149 of the Income-tax Act, 1961 is considered 'issued' only when an overt act is made to dispatch it to the addressee, not merely when it is generated on the Income Tax Business Application (ITBA) portal.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2026.

Also referred to as

Suman Jeet Agarwal v. ITO · Section 148 notice · Section 149 · date of issue · dispatch of notice · reassessment notice · Income Tax Business Application portal · ITBA · limitation for notice · deemed issue · overt act of dispatch

Also reported as

143 Taxmann.com 11290 Taxmann 493

Sections most often in play

Section 1961 Section 147 Section 148 Section 148A Section 143(3)Section 149 Section 144B Section 144

Issues it is cited on

section 282a section 149a section 148 notice section 149(1)(c)section 282 section 163 section 149(1)(a)section 148a(a)section 149(1)section 148a(b)specified authority section 148a

Judgments citing Suman Jeet Agarwal v. ITO

SANDHYA SINGH ,BHOPAL vs. ITO (2)(3), BHOPAL

In the result, the appeal of the assessee in ITA No

ITA 585/IND/2025[2014-15]Status: DisposedITAT Indore17 Apr 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Sandhya Singh Nfac, 121, Rohit Nagar, New Delhi बनाम/ Bawadia Kala, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aycps9215K Assessee By Shri Gagan Tiwari & Ms. Priyal Jain, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.03.2026 Date Of Pronouncement 17.04.2026

Section 139Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 69A

…AM. In those facts and circumstances, the Hon’ble Delhi High Court held as under:- “17. Section 149(1) of the Act proscribes issuance of notice beyond the period as stipulated in the said section. In Suman Jeet Agarwal v. Income Tax Officer and Ors.: (2022) 449 ITR 517, the Coordinate Bench of this Court had considered the question regarding as to the date of issue of a notice under Section 148 of the Act for ascertaining the period of limitation for issuance of such a notice. We consider it apposite to refer to the following extracts of the said decision: "25. Question No. (I) : Whether the jurisdictional Asse…

RED FORT SHAHJAHAN PROPERTIES P.LTD,NEW DELHI vs. ACIT, CIRCLE-19(1), NEW DELHI

In the result, both the appeals filed by the assessee are partly allowed as indicated above

ITA 2008/DEL/2022[201-18]Status: DisposedITAT Delhi17 Apr 2026

Bench: Shri C.N. Prasad & Shri M. Balaganesh, Accontant Member

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 254

…n the date and time the said directions were uploaded on the portal. Hence, the same must be treated to be a “receipt” by the recipient, i.e., the Assessing Officer on the same day, i.e., June 30, 2022. (See paragraph 26.7 of Suman Jeet Agarwal v. ITO [(2022) 449 ITR 517 (Delhi); 2022 SCC OnLine Del 3141.] , where the Delhi High Court poignantly held that the portal of the Department is the “computer resource in the control of the Department”). 32. In view of the forgoing discussion, there is no cavil of doubt that the Assessing Officer received the Dispute Resolution Panel's directions on June 30, 2022 and, ther…

RED FORT SHAHJAHAN PROPERTIES P.LTD,NEW DELHI vs. ACIT, CIRCLE-19(1), NEW DELHI

In the result, both the appeals filed by the assessee are partly allowed as indicated above

ITA 2007/DEL/2022[2014-15]Status: DisposedITAT Delhi17 Apr 2026AY 2014-15

Bench: Shri C.N. Prasad & Shri M. Balaganesh, Accontant Member

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 254

KOCH BUSINESS SOLUTIONS INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(3)(1), BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 1844/BANG/2024[2020-21]Status: DisposedITAT Bangalore01 Apr 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, A.RFor Respondent: Dr. Divya K.J., D.R

Section 143(3)

…te and time the said directions were uploaded on the portal. Hence, same must be treated to be a ‘receipt’ by the recipient i.e., the assessing officer on the same day i.e., 30.06.2022. (See paragraph No.26.7 of Suman Jeet Agarwal v. Income-tax Officer (2022) 449 ITR 517, where the Delhi High Court poignantly held that the portal of the department is the ‘computer resource in the control of the department’). 32. In view of forgoing discussion, there is no cavil of doubt that assessing officer received the DRP’s directions on 30.06.2022 and therefore, the limitation must be counted from that date and not from 05.0…

TUNGABHADRA PATTINA SOUHARDA SAHAKARI SANGHA NIYAMITHA,SINDHANUR vs. INCOME TAX OFFICER, WARD -1, RAICHUR

In the result, the appeal filed by the assessee is allowed

ITA 1844/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, A.RFor Respondent: Dr. Divya K.J., D.R

Section 143(3)

SUMITRA DEVI,GURGAON vs. ITO,WARD 4(1),GURGAON, GURGAON

ITA 2499/DEL/2025[2013-14]Status: DisposedITAT Delhi11 Mar 2026AY 2013-14

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. M.R. Sahu, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR

Section 144Section 147Section 148Section 148(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B', NEW DELHI BEFORE SH. S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER ITA No. 2499/Del/2025 (Asstt. Year :2013-14) SUMITRA DEVI, C/O M.R. SAHU, HOUSE NO. 651, 1ST FLOOR, SECTOR-10A, NEAR G.D. GOENKA PUBLIC SCHOOL, GURGAON-122001 HARYANA (PAN: AVPPD4710N) (Appellant) VS. ITO, WARD 4(1), GURGAON (Respondent) ASSESSEE BY : Sh. M.R. Sahu, CA Respondent by : Sh. Rajesh Kumar Dhanesta, Sr. DR. Date of Hearing Date of Pronouncement 23.02.2026 11.03.2026 ORDER PER SUDHIR KUMAR, JM: This appeal by the Assessee against the order dated 25.3.2025…

ITO 13(2)(1), MUMBAI vs. SKA SALES PRIVATE LIMITED, MUMBAI

ITA 5967/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Prakash Jhunjhunwala &For Respondent: Shri Nakul Agrawal

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

…er Section 148 of the Act becomes the focal point of the dispute. 10. We note that identical issue had come up for consideration before the Hon’ble Delhi High Court in the case of Suman Jeet Agarwal vs. Income-tax Officer [2023] 290 Taxman 493 (Delhi)/[2022] 449 ITR 517 (Delhi)[27-09-2022] [2022]. The Hon’ble Delhi High Court held that date/time stamp of dispatch of notice as reflected on the Income Tax Business Application (ITBA) Portal would be determinative of the date of issuance/dispatch of notice. If the date and time of dispatch as per ITBA Portal is on or after 1st of April, 2021, the notices issued by t…

SKA SALES PVT LTD,MUMBAI vs. INCOME TAX OFFICSR, WARD 13(2)(1), MUMBAI

ITA 5527/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Section 143(3)Section 144BSection 147Section 148Section 148ASection 68Section 69Section 69C

…der Section 148 of the Act becomes the focal point of the dispute. 10. We note that identical issue had come up for consideration before the Hon'ble Delhi High Court in the case of Suman Jeet Agarwal vs. Income-tax Officer [2023] 290 Taxman 493 (Delhi)/[2022] 449 ITR 517 (Delhi)[27-09-2022] [2022]. The Hon'ble Delhi High Court held that date/time stamp of dispatch of notice as reflected on the Income Tax Business Application (ITBA) Portal would be determinative of the date of issuance/dispatch of notice. If the date and time of dispatch as per ITBA Portal is on or after 1st of April, 2021, the notices issued by t…

KANHA SOFTECH PRIVATE LIMITED,UTTAR PRADESH vs. ACIT, CENTRAL-CIRCLE-I, NOIDA

In the result, the appeal of the Revenue is dismissed

ITA 5573/DEL/2025[2015-16]Status: DisposedITAT Delhi12 Feb 2026AY 2015-16

Section 142(1)Section 147Section 148Section 148A

…reat the said notice as issued u/s 148A(b) of the Act and due procedure as prescribed u/s 148A must be followed which has not been done in the instant case. The Hon'ble Jurisdictional High Court in the case of Suman Jeet Agarwal and Ors. vs. ITO & Ors. [2022] 449 ITR 517 (Del.) under identical circumstances has held that the notice issued u/s 148 prior to amendment and was served upon the assessee after the amendment, therefore, the same has to be treated as notice u/s 148A(b) and if the said procedure is not followed, the same is liable to be quashed. The relevant extract of the Hon'ble Jurisdictional High Court…

MANSOOR BAITHA,DELHI vs. ITO WARD 62 (1) - JAO, DELHI

ITA 8829/DEL/2025[2017-18]Status: DisposedITAT Delhi27 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 8828/Del/2025 : Asstt. Year: 2017-18 Ita No. 8829/Del/2025 : Asstt. Year: 2017-18 Mansoor Baitha, Vs Income Tax Officer, 25, 1St Floor, Opp. Electricity Office, Ward-62(1), Rani Jhansi Road, Motia Khan, New Delhi-110002 New Delhi-110055 (Appellant) (Respondent) Pan No. Bldpb8793G Assessee By: Sh. Deepak Oswal, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 27.01.2026 Date Of Pronouncement: 27.01.2026 Order These Assessee’S Twin Appeals For Assessment Year 2017- 18 Arise Against The Cit(A)/Nfac, Delhi’S Din & Order Nos. Itba/Nfac/S/250/2025-26/1080998632(1) & 1080998762(1) Dated 22.09.2025, In Proceedings U/S 147/144 Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Deepak Oswal, CAFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 8828/Del/2025 : Asstt. Year: 2017-18 ITA No. 8829/Del/2025 : Asstt. Year: 2017-18 Mansoor Baitha, Vs Income Tax Officer, 25, 1st Floor, Opp. Electricity Office, Ward-62(1), Rani Jhansi Road, Motia Khan, New Delhi-110002 New Delhi-110055 (APPELLANT) (RESPONDENT) PAN No. BLDPB8793G Assessee by: Sh. Deepak Oswal, CA Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 27.01.2026 Date of Pronouncement: 27.01.2026 ORDER These assessee’s twin appeals for Assessment Year 2017- 18 arise against t…

THALLA SRISAILAM GOUD,IBRAHIMPATNAM vs. INCOME TAX OFFICER, WARD 9(1), HYDERABAD

In the result, the appeal of the assessee in ITA No

ITA 589/HYD/2024[2013-14]Status: DisposedITAT Hyderabad07 Jan 2026AY 2013-14

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Respondent: Ms. U. Mini Chandran, CIT-DR and Ms. Payal Gupta, SR-DR

Section 147Section 148

…on or after 01.04.2021.” 10. On perusal of above, we find that after analysing the entire law relating to issuance of notice under section 148 of the Act, and relying upon the judgment of the Hon’ble Delhi High Court in the case of Suman Jeet Agarwal v. ITO (449 ITR 517), the Hon’ble Telangana High Court has held that the date and time mentioned in the email by which the notice is communicated to the assessee shall be treated as the date of issuance of the notice for the purposes of section 148 of the Act. The Hon’ble High Court has further held that mere uploading or generation of the notice on the Income-tax p…

DESU ENTERPRISES,ONGOLE vs. ITO., WARD-1, ONGOLE

In the result, the appeal of the assessee in ITA No

ITA 549/HYD/2024[2015-16]Status: DisposedITAT Hyderabad07 Jan 2026AY 2015-16

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.549 & 589/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 & 2013-14) 1. M/S. Desu Enterprises, Ongole (A.P.) Pan: Aagfd1940C 2. Thalla Srisailam Goud, Ibrahimpatnam. Pan: Αιτpg3044K (Appellants) Vs. Income Tax Officer, Ward-1, Ongole. Income Tax Officer, Ward 9(1), Hyderabad. (Respondents) निर्धारिती द्वारा / Assessees By: राजस्व द्वारा / Revenue By: Shri Sashank Dundu, Advocate Ms. U. Mini Chandran, Cit-Dr & Ms. Payal Gupta, Sr-Dr सुनवाई की तारीख / Date Of Hearing: 06/11/2025 घोषणा की तारीख / Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Appeals Are Filed By M/S. Desu Enterprises & Shri Thalla Srisailam Goud (“The Assessees”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 26.02.2024 & 09.04.2024 For The A.Ys. 2015-16 & 2013-14 Respectively. Since The Issues Involved In These Two Appeals Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Respondent: Shri Sashank Dundu, Advocate

Section 147Section 148

…on or after 01.04.2021." 10. On perusal of above, we find that after analysing the entire law relating to issuance of notice under section 148 of the Act, and relying upon the judgment of the Hon'ble Delhi High Court in the case of Suman Jeet Agarwal v. ITO (449 ITR 517), the Hon'ble Telangana High Court has held that the date and time mentioned in the email by which the notice is communicated to the assessee shall be treated as the date of issuance of the notice for the purposes of section 148 of the Act. The Hon'ble High Court has further held that mere uploading or generation of the notice on the Income-tax p…

NEPTUNE FINCOT PVT LTD,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE 15(1)(2), MUMBAI

In the result, the assessee succeeded ground no

ITA 3946/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 Jan 2026AY 2014-15

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 144BSection 147Section 148Section 254(1)Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER& SHRI ARUN KHODPIA, ACCOUNTANT MEMBER (Physical hearing) Neptune Fincot Pvt. Ltd. ACIT, Circle-15(1)(2), Mumbai C/101, 1st Floor, Shankar Dhan Plaza, Room No. 483, 4th Floor, Aayakar Vs Jawaharlal Nehru Road, Mulund (W), Bhavan, M.K. Road, New Marine Maharashtra - 400 067. Lines, Mumbai-400 020. PAN : AACCN0451F Appellant / Assessee Respondent / Revenue Assessee by Shri V.G. Vinde & Shri Kumar Kale CA’s Revenue by Shri Leyaqat Ali Aafaqui, Sr. DR Date of Institution 08.08.2024 Date of hearing 06.01.2026 Date of pro…

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, all the three appeals of the assessee for the A

ITA 3047/CHNY/2025[2016-17]Status: DisposedITAT Chennai01 Jan 2026AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Mr. R. Venkataraman, FCA &For Respondent: Shri. ARV Sreenivasan, CIT

Section 144Section 147Section 148Section 148ASection 201Section 69A

…to be undertaken in accordance with the procedure prescribed u/s.148A of the Act, having regard to the fact that the notice was digitally signed and issued on 01.04.2021. 31. On identical facts, the Hon’ble Delhi High Court in Suman Jeet Agarwal v. ITO [2022] 449 ITR 517 (Del) has categorically held that the date of the digital signature constitutes the date of issuance of the notice. The Hon’ble Court further observed that where the notice is digitally signed on 01.04.2021, it shall necessarily be construed as a notice issued u/s.148A(b) of the Act, in :-15-: ITA. No:3046, 3047 & 3048/Chny/2025 consonance with…

SHIVAADITIYA JEMS AND JEWELLERY PVT LTD,MORADABAD vs. ITO ,WARD-2(1), MORADABAD

In the result, appeal of the Revenue is dismissed

ITA 5661/DEL/2024[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 147Section 148Section 148ASection 151ASection 69C

…31.03.2021 has been digitally signed on 31.03.2021, however dispatched on or after 01.04.2021 by speed post/ email and needs to be construed as being issued after 01.04.2021 as held by Hon’ble Delhi High Court in the case of Suman Jeet Agarwal Vs. ITO (2022) 449 ITR 517 (DEL). And procedure as per Ashish Agarwal needs to be followed, the Hon’ble Delhi High Court has held as under :- “31.3 Category C : The petitions challenging notices falling under Category “C” which were digitally signed on 31st of March 2021, are disposed of with the direction to the JAO’s to verify and determine the date and time of dispatch…

INCOME TAX OFFICER WARD-2(1) MORADABAD, MORADABAD vs. SHIVAADITIYA JEMS AND JEWELLERY PRIVATE LIMITED, MORADABAD

In the result, appeal of the Revenue is dismissed

ITA 4857/DEL/2024[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 147Section 148Section 148ASection 151ASection 69C

CHANDANAM SANGAIH & SON,NARSARAOPETA vs. INCOME-TAX OFFICER, WARD-1, NARSARAOPETA

In the result, the appeal by the assessee is allowed

ITA 567/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2017-18

Bench: Shri Sandeep Singh Karhail, Hon’Ble & Shri Omkareshwar Chidara, Hon’Bleआयकर अपील सं./I.T.A. No. 567/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2017-18) Chandanam Sangaih & Son V. Income Tax Officer – Ward - 1 7-159/47, Innaiah Gari Building Income Tax Office, 12-9-22/A Vinukonda Road Prakashnagar, Narsaraopeta Narasaraopeta, Guntur – 522601 Guntur – 522601 Andhra Pradesh Andhra Pradesh [Pan: Aalfc8018M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(2)Section 147Section 148Section 250

…cause notice under section 148A(b) of the Act as per the decision of the Hon’ble Supreme Court in the case of UOI v. Ashish Agarwal (supra). We find that the Hon’ble Delhi High Court reached similar conclusions in Suman Jeet Agarwal v. ITO, reported in (2022) 449 ITR 517 (Delhi). The relevant findings of the Hon’ble Delhi High Court are reproduced as follows: - “31.5 Category 'E': The petitions challenging Notices falling under category 'E' which were manually despatched, are disposed of with the direction to the JAOs to determine in accordance with the law laid down in this judgment, the date and time when the…

RUCHIE MITTAL,DELHI vs. DCIT CC-1, FARIDABAD

In the result, the appeal is allowed

ITA 2683/DEL/2025[2013-14]Status: DisposedITAT Delhi16 Dec 2025AY 2013-14

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2683/Del/2025 िनधा"रणवष"/Assessment Year:2013-14 बनाम Ruchie Mittal, Dcit Plot No.10-11, 2Nd Floor, Vs. Central Circle-1, Nelson Mandela Marg, Vasant Kunj, Faridabad, Haryana. Delhi. Pan No.Addpg0409P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 148ASection 250Section 69Section 69A

…he various provisions of the new procedure to illustrate the point that the Ld. AO has persisted with the old procedure in spite of the notice being issued on 01.04.2021. The Ld. AR read out from various portions of the case of Suman Jeet Agarwal reported in 449 ITR 517 (Del). The Ld. AR emphasized the point that the date of issue in the ITBAPortal was the material date and this view was supported by the case of Suman Jeet Agarwal (supra). 2.1 Since the fact regarding the date of issue of notice goes to the root of the matter, hence, it was decided to adjudicate this first. 2.2 The Ld. DR relied on the orde…

INCOME TAX OFFICER, WARD 46(1), NEW DELHI, NEW DELHI vs. MAM RAJ CHUNNI LAL EXIM, NEW DELHI

In the result the appeal of the Revenue is dismissed and the cross objection of the assessee is partly allowed

ITA 3573/DEL/2024[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2016-17 Income Tax Officer, Vs Mam Raj Chunni Lal Exim Ward- 46 (1) Shop No. 5183, Ground New Delhi Floor, Lahori Gate, Naya Bazar, Delhi -110006 Pan No.Aaxfm0533B (Appellant) (Respondent)

Section 133ASection 147Section 148Section 148ASection 149(1)Section 151Section 151A

…nction accorded by the PCIT would not sustain.. 6. Dealing with an identical question, we had in Abhinav Jindal HUF v. Commissioner of Income Tax and Ors held as under:- “30. Tested on the principles which were enunciated in Suman Jeet Agarwal v. ITO [(2022) 449 ITR 517 (Delhi); 2022 SCC OnLine Del 3141.], the petitioners would appear to be correct in their submission of the date liable to be ascribed to the impugned notices and those being viewed as having been issued and dispatched after April 1,2021. However, and in our considered opinion, the same would be of little relevance or significance when one bears i…

AAKANKSHA GUPTA,DELHI vs. ITO WARD 69(1), NEW DELHI, DELHI

In the result, the appeal filed by the Assessee is allowed

ITA 2763/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Dec 2025AY 2017-18

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2763/Del/2025 िनधा"रणवष"/Assessment Year: 2017-18 बनाम Aakanksha Gupta, Income Tax Officer, C/O Ca Vaibhav Goel, Vs. Ward 69(1), 78, Navyug Market, 1St Floor, New Delhi. Ghazaibad, Uttar Pradesh. Pan No.Amhpg9430D अपीलाथ" Appellant ""यथ"/Respondent

Section 143(2)Section 144BSection 147Section 148Section 149Section 250Section 54

…valid notice u/s 148 of the Act was not served on the assessee and hence the consequential proceedings would be bad in law. The two cases relied upon by the assessee also deserve to be mentioned in some detail. In the case of Sumanjeet Aggarwal reported in 449 ITR 517 (Del.) the head note may be extracted for reference: 5 “Section 149 read with section 148 of the Income-tax Act, 1961 and section 13 of the Information technology Act, 2000 - Income escaping assessment - Time limit for issuance of notice (Validity of notice) - Assessment years 2013-14 to 2017-18 - Sections 147, 148, 149 and 151 were amended vid…

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