How many judgments cite Union of India v. Ashish Agarwal?

524 judgments on BharatTax cite Union of India v. Ashish Agarwal (444 ITR 1), spanning 2022 to 2026.

Which sections of the Income Tax Act does Union of India v. Ashish Agarwal come up under?

It is most often cited in judgments turning on Section 148, Section 147, Section 148A, Section 151, Section 149, Section 144B.

Union of India v. Ashish Agarwal

444 ITR 1Supreme Court of India2022#126 most cited

What is Union of India v. Ashish Agarwal authority for?

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

524

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2022 to 2026.

Also referred to as

Union of India v. Ashish Agarwal · Section 148 notice validity · reassessment notices after April 1 2021 · amended reassessment provisions · Section 148A(b) conversion · Article 142 directions · unamended Section 148 · reopening assessment procedure · Section 148A(d) order · time limit for reassessment

Also reported as

138 Taxmann.com 642022 SCC OnLine SC 543286 Taxmann 1831 SCC 617

Sections most often in play

Section 148 Section 147 Section 148A Section 151 Section 149 Section 144B Section 143(3)Section 250

Read the full judgment

Issues it is cited on

section 149a(c)section 149a(d)section 148a(c)section 149a section 151(i)section 148 notice section 149(1)(a)section 148a(a)section 3(1)section 151(ii)order under section 148a(d)section 149(1)

Judgments citing Union of India v. Ashish Agarwal

Income Tax Officer Ward-2(2)(1), Ghaziabad vs. Vikas Sharma, Ghaziabad

In the result, the appeal filed by the Revenue in AY 2013-14 is dismissed

ITA 3495/DEL/2025[2013-14]Status: DisposedITAT Delhi30 Dec 2025AY 2013-14

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR

Section 143(3)Section 147Section 148Section 148A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER Income Tax Officer, vs. Vikas Sharma, Ward 2 (2)(1), Ghaziabad. 15/103, Vashundhara, Ghaziabad – 201 012. (PAN : AVJPS8784R) Date of Hearing : 06.10.2025 Date of Order : 30.12.2025 Income Tax Officer, vs. Vikas Sharma, Ward 2 (2)(1), Ghaziabad. 15/103, Vashundhara, Ghaziabad – 201 012. (PAN : AVJPS8784R) Date of Hearing : 09.10.2025 Date of Order : 30.12.2025 (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Salil Kapoor, Advocate Shri Sumit Lalchandani, Advocate M…

DCIT, Central Circle 3, New Delhi vs. Ameeta Mehra, New Delhi

The Appeal of the Revenue is dismissed

ITA 3568/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Dec 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(3)Section 147Section 148Section 148A

…reopened and a notice u/s 148 of the Act came to be issued on 07/04/2021 which has been subsequently treated as notice issued u/s 148A(b) of the Act as per the Judgment of Hon'ble Supreme Court in the case of Union of India vs. Aashish Agarwal and reported 2022 SCC OnLine SC 543. In compliance with the Judgment of Hon'ble Supreme Court in the case of Union of India Vs. Aashish DCIT Vs. Ameeta Mehra Agarwal (supra), the copy of the reasons recorded served on the Assessee on 20/05/2022, wherein it was alleged in the reasons recorded that the Assessee had unexplained credit in the bank account amounting to Rs.…

Waves Tradeline Private Limited, Ahmedabad vs. The ITO, Ward-4(1)(1), Ahmedabad

The appeals of the assessee are allowed

ITA 1230/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 68

…ed by limitation and the jurisdiction assumed by the Assessing Officer was contrary in law in the light of binding decision of Hon’ble Supreme Court in the cases of Union of India vs. Rajeev Bansal, 167 taxamann.com 70 (SC), Union of India vs. Ashish Agarwal, 444 ITR 1 (SC) and Deepak Steel and Power Limited (supra) as well as the judgement of jurisdictional Gujarat High Court in the case of Narendra Maganlal Purohit & Others (supra). There is no dispute in the fact that the first notice under Section 148 of the Act for A.Y. 2015-16 was issued on 07.06.2021. The Hon’ble Supreme Court in the case of Deepak Steel a…

Waves Tradeline Private Limited, Ahmedabad vs. The ITO, Ward-4(1)(1), Ahmedabad

ITA 1229/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 68

…ed by limitation and the jurisdiction assumed by the Assessing Officer was contrary in law in the light of binding decision of Hon'ble Supreme Court in the cases of Union of India vs. Rajeev Bansal, 167 taxamann.com 70 (SC), Union of India vs. Ashish Agarwal, 444 ITR 1 (SC) and Deepak Steel and Power Limited (supra) as well as the judgement of jurisdictional Gujarat High Court in the case of Narendra Maganlal Purohit & Others (supra). There is no dispute in the fact that the first notice under Section 148 of the Act for A.Y. 2015-16 was issued on 07.06.2021. The Hon'ble Supreme Court in the case of Deepak Steel a…

Waves Tradeline Private Limited, Ahmedabad vs. The ITO, Ward-4(1)(1), Ahmedabad

The appeals of the assessee are allowed

ITA 1228/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 68

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1592/HYD/2025[2022-23]Status: DisposedITAT Hyderabad24 Dec 2025AY 2022-23

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 132Section 147Section 148

…o be done by way of an automated faceless mechanism, all proceedings of assessment drawn subsequently have to be by following the same mechanism. Further, the Hon'ble Supreme Court in the case of UOI v. Ashish Agarwal [2022] 138 taxmann.com 64/286 Taxman 183/ 444 ITR 1 (SC)/2022 SCC OnLine SC 543, in very categorical terms has held as under: "Thus, the new provisions substituted by the Finance Act, 2021 being remedial and benevolent in nature and substituted with a specific aim and object to protect the rights and interest of the assessee as well as and the same being in public interest, the respective High Court…

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1591/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Section 132Section 147Section 148

Naresh Amratlal Shah, Mumbai vs. ITO Ward-27(2)(1), Mumbai

In the result, the appeal of the In the result, the appeal of the Assessee is allowed allowed

ITA 6142/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Dec 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Respondent: Assessee by Shri Jitendra Singh & Shri

Section 115BSection 148Section 69A

…/MUM/25 7 Naresh Amratlal Shah Court in the case of Union of 04/05/2022 04/05/2022 India vs Ashish Agarwal 4 Show cause notice was issued in accordance with the 27/05/2022 27/05/2022 decision in the case of Union of India vs Ashish Agarwal reported in (2022) 444 ITR 1 (SC) and the appellant was granted time upto 10.06.2022. 5 Order passed by the Ld. JAO u/s 148/A(d) of the Act 22/07/2022 22/07/2022 6 Notice issued u/s 148 of the Act – New Provisions. 22/07/2022 22/07/2022 The Ld. AR, during the course of arguments, submitted The Ld. AR, during the course of arguments, submitted The Ld. AR, during the course of…

Punya Sthali Tirth Trust, Uttar Pradesh vs. ITO Ward (Exemption) Ward 2(4), Delhi

Appeal is allowed

ITA 5713/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Punya Sthali Tirth Trust, Vs. Income Tax Officer, Gang Nahar Road, Ward (Exemption) - 2(4), Muradnagar, Delhi Uttar Pradesh Pan: Aabtp8479P (Appellant) (Respondent)

Section 13ASection 147Section 148Section 148ASection 151Section 29A

…after 31.03.2021 but under the unamended provisions relating to the re-assessment of income that had escaped assessment. 4. The Revenue appealed the decisions rendered by various High Courts to the Supreme Court of India. In Union of India v. Ashish Agarwal: 2022 SCC OnLine SC 543 - which was one of such appeals arising from the decision of the Allahabad High Court - the Supreme Court delivered its decision on 04.05.2022, whereby it concurred with the view that the amended provisions which came into force after 31.03.2021 would be applicable to notices issued thereafter. However, the Supreme Court also issued ce…

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, both appeals of the assessee are allowed

ITA 5114/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 68

…2021 wet. 01.04.2021. Notice 14 of the Act as per the old provisions of section 148 of the Act applicable till 31.03.2021 should have been issued only upto 31.03.2021. The issue stands settled by the Hon'ble Supreme Court in Union of India vs Ashish Agarwal, 444 ITR 1 (SC) The assessee company was part of the litigations. The AO has issued notice u/s 148A(b) on 27.05.2022 and on 28.07.2021 order was passed u/s 148A(d) and issued notice is 148 of the Act on the same date, ie, on 28.07.2022 in AY 2016-17 and while in AY 2017-18 on 27.07.2022 order was passed u/s 148A(d) and issued notice w/s 148 of the Act on 28.0…

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, both appeals of the assessee are allowed

ITA 5113/DEL/2025[2016-17]Status: DisposedITAT Delhi24 Dec 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 68

Roy Banerjee Development Pvt. Ltd., Kolkata vs. I.T.O., Ward - 1(1), Kolkata

The appeal of the assessee is allowed

ITA 1584/KOL/2025[2015-2016]Status: DisposedITAT Kolkata23 Dec 2025AY 2015-2016

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 147Section 148Section 148ASection 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH,KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER I.T.A. No.1584/Kol/2025 (Assessment Year 2015-16) Roy Banerjee Development Private Limited, 1B, Malanga Lane, Kolkata - 700012 [PAN: AADCR3483N] ..……..…...……………....Appellant vs. ITO Ward 1(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata – 700069 ................................ Respondent Appearances by: Assessee represented by : Soumitra Choudhury, Advocate Department represented by : S.B. Chakraborthy, Addl. CIT, Sr. DR Date of concluding the hearing : 01.12.2025…

Gamnaram Okhaji Prajapati, Mumbai vs. Dy. CIT Circle 1(2)(1), Mumbai

Appeal is allowed

ITA 6790/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-16

For Appellant: Shri Dinesh ShahFor Respondent: Shri Swapnil Choudhary

Section 115BSection 144Section 144BSection 147Section 148Section 148ASection 153CSection 234Section 234BSection 69A

…to amendment introduced by the Finance Act, 2021 [for short 'the Old Regime'] between 1st April 2021 and 30th June 2021 which were quashed by the various High Courts. The Hon'ble Supreme Court noted that in the case of Union of India v. Ashish Agarwal [2023] 1 SCC 617, exercising powers under Section 142 of the Constitution, the Apex Court had directed that the reassessment notices issued under Section 148 of the Old Regime shall be deemed to notices issued under Section 148A(b) of the New Regime [i.e., Section 148/148A and other applicable provisions of the Act as amended by the Finance Act, 2021]. The Assessin…

Shantilal Narottamdas Panchal, Malad East vs. ITO-41(3)(4), Mumbai, Bandra Kurla Complex

Appeal is allowed

ITA 3570/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18

Bench: Him.

For Appellant: Shri Ravindra PoojaryFor Respondent: Shri Bhagirath Ramawat

Section 144BSection 147Section 148Section 148ASection 151Section 56(2)(vii)

…l in Civil Appeal 8629 of 2024. In this case, the first notice under section 148 of the Act was issued on 3-05-2021 and subsequently following the directions contained in the judgment of Hon'ble Supreme Court in case of Union of India vs Ashish Agarwal (2023) 1 SCC 617, the said notice was deemed to be a show-cause notice under section 148A(b) of the new regime as amended by Finance Act of 2021. Subsequently, following the due procedure as clarified by Hon'ble Supreme Court in Ashish Agarwal case (supra) a notice under section 148 was issued on 21-07-2022, after passing an order u/s 148A(d) of the Ac, following t…

Brij Bhushan Kalia, Up vs. ITO, Ward-61(1), Delhi

Appeal is allowed in above terms

ITA 7624/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Dec 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 7624/Del/2025 : Asstt. Year: 2017-18 Brij Bhushan Kalia, Vs Income Tax Officer, C/O Chaurasia & Associates, Ward-61(1), C-2302, Ats Advantage, New Delhi-110002 Indirapuram, Ghaziabad-201014 (Appellant) (Respondent) Pan No. Aaepk9068Q Assessee By: Sh. Venketesh Chaurasia, Adv. Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081596042(1) Dated 09.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Venketesh Chaurasia, AdvFor Respondent: Sh. Amit Shukla, Sr. DR

Section 13ASection 147Section 148Section 148ASection 29A

…after 31.03.2021 but under the un-amended provisions relating to the re-assessment of income that had escaped assessment. 4. The Revenue appealed the decisions rendered by various High Courts to the Supreme Court of India. In Union of India v. Ashish Agarwal: 2022 SCC OnLine SC 543 - which was one of such appeals arising from the decision of the Allahabad High Court - the Supreme Court delivered its decision on 04.05.2022, whereby it concurred with the view that the amended provisions which came into force after 31.03.2021 would be applicable to notices issued thereafter. However, the Supreme Court also issued ce…

Asb Designs LLP, New Delhi vs. Central Circle 26, Delhi

Appeal is allowed in above terms

ITA 6691/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 6691/Del/2025 : Asstt. Year: 2018-19 Asb Designs Llp, Vs Dcit, B-223, Naraina Industrial Area, Central Circle-26, New Delhi-110028 New Delhi-110001 (Appellant) (Respondent) Pan No. Abdfa1476G Assessee By: Sh. Sandeep Vijh, Ar Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 23.12.2025 Order This Assessee’S Appeal For Assessment Year 2018-19 Arises Against The Cit(A)-29, New Delhi’S Order Dated 22.08.2025, In Case No. Cit(A), Delhi-29/10559/2017-18, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Sandeep Vijh, ARFor Respondent: Sh. Amit Shukla, Sr. DR

Section 13ASection 147Section 148Section 148ASection 29A

Income Tax Officer, Hisar vs. Neem Chand, Adampur

In the result, the appeal filed by the Revenue is dismissed

ITA 2404/DEL/2025[2015]Status: DisposedITAT Delhi23 Dec 2025

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2015-16 Income Tax Officer, Vs. Neem Chand, C/O Babu Lal Surender Aaykar Bhawan, Sector-14, Kumar, 112 Anajmandi, Adampurandi Hisar ( Haryana ) Pin: 125 052 Haryana, India Pan :Ahfpc5351C (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 148Section 148ASection 149Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘D’ NEW DELHI BEFORE SHRI M BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Assessment Year: 2015-16 Income Tax Officer, Vs. Neem Chand, C/o Babu Lal Surender Aaykar Bhawan, Sector-14, Kumar, 112 Anajmandi, Adampurandi Hisar ( Haryana ) PIN: 125 052 Haryana, India PAN :AHFPC5351C (Appellant) (Respondent) Department by Shri Lalit Mohan, CA. Assessee by Shri Ajay Kumar Arora, Sr. DR Date of hearing 11.12.2025 Date of pronouncement 23.12.2025 ORDER PER VIMAL KUMAR, JUDICIAL MEMBER: The appeal filed by the Department of Revenue is against o…

Dy. Commissioner of Income Tax, Jaipur, Rajasthan, India vs. Manav Pansari, Rajasthan, India

17. In view of the above discussion, we do not find any merit in the appeal filed by the department

ITA 1188/JPR/2025[2013-14]Status: DisposedITAT Jaipur22 Dec 2025AY 2013-14

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपीलसं. / ITA No. 1188/JPR/2025 निर्धारण वर्ष / AssessmentYear : 2013-14 Dy. Commissioner of Income Tax, Jaipur. बनाम Manav Pansari Vs. A-7, Showromm Sethi colony, TA Main Agra Road, Jaipur. अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No. AARPP1288Q निर्धारिती की ओरसे / Assessee by : Shri Vishnu Khandelwal, CA. राजस्व की ओरसे / Revenue by: Mrs. Alka Gautam, CIT. सुनवाई की तारीख / Date

For Appellant: Shri Vishnu Khandelwal, CAFor Respondent: Mrs. Alka Gautam, CIT

Section 147Section 148Section 148ASection 69A

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B-Bench” JAIPUR Jherh vUuiw.kkZ xqIrk] ys[kk lnL; ,oa Jh ujsUnz dqekj] U;kf;d lnL; ds le{k BEFORE: SMT. ANNAPURNA GUPTA, AM & SHRI NARINDER KUMAR, JM vk;dj vihyla-@ITA No. 1188/JPR/2025 fu/kZkj.k o"kZ@AssessmentYear : 2013-14 Dy. Commissioner of Income Tax , cuke Manav Pansari Jaipur. Vs. A-7, Showromm Sethi colony, TA Main Agra Road, Jaipur. LFkk;hys[kk la-@thvkbZvkjla-@PAN/GIR No. AARPP1288Q vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assessee by : Shri Vishnu Khandelwal, CA. jktLo dh vksjls@Revenue…

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

…amendment by the Finance Act, 2021 w.e.f. 01.04.2021, came up for consideration before the Hon’ble Supreme Court in the case of the UOI v. Ashish Agarwal, the Hon’ble Supreme Court in the aforesaid case vide its judgement dated 04.05.2022, reported in (2022) 444 ITR 1 (SC) held that these extended re-assessment notices issued under the old law shall be deemed to be a show-cause notices issued under section 148A(b) of the Act of the new law and directed the Assessing Officers to follow the procedure with respect to such notices. 13. We find that in order to implement the decision of the Hon’ble Supreme Court in…

Harish Banga, Hisar vs. Assessment Unit, New Delhi

In the result, both the substantial ground of appeal is allowed

ITA 4893/DEL/2025[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Pawan Singhassessment Year: 2018-19 (Physical Hearing) Harish Banga, Assessment Unit, 264, Bank Colony, Hisar, Vs. Faceless Assessment Unit Haryana – 125001. Income Tax Department, Pan – Abqpb 8845 F New Delhi-110001. (Appellant) (Respondent) Present For: Assessee By : Shri H.K. Batra, Ca & Shri Naman Chawla, Ca Revenue By : Shri Virender Kumar Singh, Sr. D.R. Date Of Hearing : 04.12.2025 Date Of Pronouncement : 19.12 .2025 O R D E R Per : Pawan Singh: This Appeal By The Assessee Is Directed Against The Order Of Cit (A) Dated 08.07.2025 Vide Assessment Year 2018-19. The Assessee Has Raised Following Grounds Of Appeal:-

For Appellant: Shri H.K. Batra, CA &For Respondent: Shri Virender Kumar Singh, SR. D.R

Section 147Section 148Section 148ASection 151ASection 56Section 57

…t's participation in assessment proceedings estopped him from challenging the validity of the notice u/s 148. The jurisdictional defect in reopening cannot be cured by participation, as held in various judicial precedents, including CIT v. Chetan Gupta (2022) 441 ITR 1 (SC). 1.6 Without prejudice, the addition made by the AO and confirmed by the Ld. CIT(A) exceeds the scope of reopening, as the notice u/s 148A(b) was issued solely for disallowance of expenses, and no new income was alleged to have escaped assessment. 2.1 The Ld. CIT(A) erred in law and on facts in confirming the disallowance of commission expen…