How many judgments cite Union of India v. Rajeev Bansal?

713 judgments on BharatTax cite Union of India v. Rajeev Bansal (469 ITR 46), spanning 2023 to 2026.

Which sections of the Income Tax Act does Union of India v. Rajeev Bansal 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. Rajeev Bansal

469 ITR 46Supreme Court of India2024#72 most cited

What is Union of India v. Rajeev Bansal authority for?

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

713

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2023 to 2026.

Also referred to as

Union of India v. Rajeev Bansal · Section 148 notice limitation · Ashish Agarwal legal fiction · TOLA applicability · reassessment jurisdiction · time-barred notice · order without jurisdiction · Section 149 · Section 148A

Also reported as

167 Taxmann.com 70301 Taxmann 238

Sections most often in play

Section 148 Section 147 Section 148A Section 151 Section 149 Section 144B Section 250 Section 144

Read the full judgment

Issues it is cited on

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

Judgments citing Union of India v. Rajeev Bansal

Mittal Homes Pvt Ltd, Delhi vs. ITO Ward-17(1), Delhi

In the result, the appeal of the Assessee is allowed

ITA 2328/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: # Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 143(1)(a)Section 148Section 148ASection 250Section 68

…aining the table for calculation of time barred notice under section 148 of the Act. It was argued that the case is covered by the judgment of Hon'ble Supreme court of India in Union of India & Ors. vs. Rajeev Bansal" (Civil Appeal No.8629/2024 etc.) [(2024) 469 ITR 46. (SC)]. It was therefore argued that since neither AO nor the Ld. CIT(A) has considered the said aspects regarding the notice under section 148 of the Act was barred by limitation, therefore, the appeal be allowed and the assessment order be quashed. - 6. We have also heard the Ld. DR who was supplied with the paper book, and after going through…

Principal Commissioner of Income Tax-1 vs. Harshad Rai Mehta

ITA/57/2023HC Orissa08 Jan 2026

Bench: MR. JUSTICE HARISH TANDON (CJ),MR. JUSTICE MURAHARI SRI RAMAN

…1 2026:CGHC:7796 NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR WPT No. 57 of 2023  Sharda Jain W/o Shikharchand Jain Aged About 56 Years Prop. Jai Bhawani Enterprises, E-430, Samta Colony, Raipur District Raipur Chhattisgarh --- Petitioner(s) versus 1. The Principal Commissioner Of Income Tax-1 Raipur Central Revenue Building, Civil Lines, Raipur District Raipur Chhattisgarh 2. The Deputy /assistant Commissioner Of Incom Tax Circle-1(1), Central Revenue Build…

Poonam Manoj Agrawal, Mumbai vs. Income Tax Officer, WD-25(3)(1), Mumbai

In the result, the Assessee’s Appeal is allowed

ITA 6018/MUM/2025[2016-17]Status: DisposedITAT Mumbai07 Jan 2026AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2016-17 Poonam Manoj Agrawal, Income Tax Officer, Wd- G-1801, Gundecha Gardens, 25 (3) (1), Bombay Gaswork Lane, Opp. Vs. Kautilya Bhavan, Bandra Ganesh Talkies, Lalbaug, Kurla Complex, Bandra, Mumbai - 400012 Mumbai - 400051 Pan – Adtpa3423D (Appellant) (Respondent) Present For: Assessee By : Shri Saiprasad K. Ghosh, Ld. A.R. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 07.01.2026 Date Of Pronouncement : 07.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 18.07.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In This Case, The Notice Dated 07.05.2021 Under Section 148 Of The Act Was Initially Issued Under The Old Act, Which Was Treated As Deemed Notice Under Section 148 (A)(B) Of The Act, In View Of The Judgment Of The Hon’Ble Apex Court In The Case Of Uoi Vs. Rajeev Bansal Reported {[2024] 167 Taxmann.Com 70} By Taking Sanction, As Per Old Provisions Of The Act, As Applicable Thereto.

For Appellant: Shri Saiprasad K. Ghosh, Ld. A.RFor Respondent: Shri Virabhadra Mahajan, SR. D.R

Section 148Section 151Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “C”, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER And SHRI JAGADISH, ACCOUNTANT MEMBER Assessment Year: 2016-17 Poonam Manoj Agrawal, Income Tax Officer, Wd- G-1801, Gundecha Gardens, 25 (3) (1), Bombay Gaswork Lane, Opp. Vs. Kautilya Bhavan, Bandra Ganesh Talkies, Lalbaug, Kurla Complex, Bandra, Mumbai - 400012 Mumbai - 400051 PAN – ADTPA3423D (Appellant) (Respondent) Present for: Assessee by : Shri Saiprasad K. Ghosh, Ld. A.R. Revenue by : Shri Virabhadra Mahajan, SR. D.R. Date of Hearing : 07.01.2026 Date of Pronouncement : 07.01.2026 O R D E R…

Nadeem Mohammed Iqbal Patni, Mumbai vs. ITO Ward 25(3)(1), Mumbai

ITA 5549/MUM/2025[2015-16]Status: DisposedITAT Mumbai07 Jan 2026AY 2015-16

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri M. SubramanianFor Respondent: Shri Pradipsinh Saktavat

Section 142Section 144BSection 147Section 148Section 148ASection 151

…r Section 148 of the Act for the Assessment Year 2015-16 has been issued after 01/04/2021 and is, therefore, without jurisdiction in view of the concession made by the Revenue before the Hon'ble Supreme Court in case of Union of India Vs. Rajeev Bansal [2024] 469 ITR 46 (SC). In support the Learned Authorised Representative for the Assessee placed on record the recent judgment of the Hon’ble Bombay High Court in the case of Cherian Nallathu Abraham Annamma vs. Income- tax Officer, International Tax, Ward-1(1)(1), Mumbai [2025] 179 taxmann.com 433 (Bombay)/[2025] 307 Taxman 367 (Bombay)[13- 10-2025]. 6. Per contr…

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

In the result, Appeal of the Assessee is allowed

ITA 5053/DEL/2025[2014-15]Status: DisposedITAT Delhi07 Jan 2026AY 2014-15

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

Section 139(1)Section 142(1)Section 144BSection 147Section 148Section 148ASection 250Section 68

…ntaining the table for calculation of time barred notice under section 148 of the Act. It was argued that the case is covered by the judgment of Hon'ble Supreme court of India in Union of India &Ors. vs. Rajeev Bansal" (Civil Appeal No.8629/2024 etc.) [(2024) 469 ITR 46. (SC)]. It was therefore argued that since neither AO nor the Ld. CIT(A) has considered the said aspects regarding the notice under section 148 of the Act was barred by limitation, therefore, the appeal be allowed and the assessment order be quashed. 7. We havealso heard the Ld. DR who was supplied with the paper book, and after going through Page…

ACIT Circle-28(1), New Delhi vs. Munjal Holdings, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5834/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 250Section 68

…ee has followed its earlier order delivered in the case of Twylight Infrastructure Pvt. Ltd. Vs. CIT reported in 2024-DHC-259-DB however, the said order was considered and set aside by the hon’ble supreme court in the case of UOI Vs. Rajeev Bansal reported in 469 ITR 46(SC). Ld. CIT DR further submits that ld. CIT(A) has not decided the issues raised by the assessee on merits therefore, the order of ld. CIT(A) be set aside and remand back to his file to decide the issues on merits. She prayed accordingly. 7. On the other hand, Ld. AR for the assessee supported the order of ld. CIT(A) and submits that notice u/s…

Global Emerging Markets India Limited, New Delhi vs. NFAC, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4050/DEL/2024[2013-2014]Status: DisposedITAT Delhi07 Jan 2026AY 2013-2014

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshglobal Emerging Markets Assessment Unit, India Limited, Income Tax Department, B-28, Pushpanjali Farms, Vs. Nfac. Bijwasan. Pan-Aaacg3233C (Appellant) (Respondent) Appellant By Ms. Prem Lata Bansal, Sr. Adv. & Shri Shivang Bansal, Adv. Respondent By Shri Rajesh Kumar Dhaneshta, Sr. Dr Date Of Hearing 03.12.2025 Date Of Pronouncement 07.01.2026

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

…at arises for our consideration is as to whether the subsequent notice issued u/s 148 of the Act on 28.06.2022 is to be treated as time barred or not in the light of decision of Hon'ble Supreme Court in the case of Union of India Vs. Rajeev Bansal reported in 469 ITR 46 (SC). In this regard, it would be appropriate to reproduce the relevant portion of the decision of the Hon'ble Supreme Court in the case of Rajeev Bansal referred (supra) as under:- “110. The effect of the creation of the legal fiction in Ashish Agarwal (supra) was that it stopped the clock of limitation with effect from the date of issuance of S…

Sunblaze Constructions Pvt. Ltd., Kolkata vs. I.T.O., Ward - 9(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1788/KOL/2025[2016-2017]Status: DisposedITAT Kolkata06 Jan 2026AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Ito, Ward 9(1) Sunblaze Constructions Pvt. Ltd. 164/1, Maniktala Main Road, Aaykar Bhawan, P-7, Kankurgachi, S.O. Kolkata- Chowringhee Square, Kolkata- Vs. 700054, West Bengal 700069, West Bengal (Appellant) (Respondent) Pan No. Aascs7903D Assessee By : Shri S.K. Tulsiyan & Ms. Puja Somani, Ars Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 17.11.2025 Date Of Pronouncement: 06.01.2026

For Appellant: Shri S.K. Tulsiyan &For Respondent: Shri S.B. Chakraborthy, DR

Section 148Section 148A

…in the following paras. 3. The assessee has raised additional ground qua the notice u/s 148 of the Act being time barred by limitation in consonance with the decision of the Hon'ble Apex Court in the case of Union of India and other Vs. Rajeev Bansal [2024] 469 ITR 46 (SC), dated 03.10.2024, which read as under:- “That the ld. AO erred in passing an order was u/s 148A(d) of the Act dt.29.7.2022 and issuing the impugned notice under section 148 of the Income-tax Act 1961 and 29.07.2012 Assessment Year 2016-17 which is beyond the surviving period of limits of decision of the Hon'ble Supreme Court in Sunblaze Con…

Naval Seth L/H Late Sh. Ghansham Dass Seth, Delhi vs. ACIT Circle-28(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 6210/DEL/2025[2016-17]Status: DisposedITAT Delhi06 Jan 2026AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Ms. Mansi Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 147Section 148Section 148ASection 151Section 250

…ITA No. 6210/DEL/2025 Naval Seth vs ACIT Circle -28(1) IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SHRI MAHAVIR SINGH, HON’BLE VICE-PRESIDENT & MRS. RENU JAUHRI, HON’BLE ACCOUNTANT MEMBER ITA No. 6210/DEL/2025; A.Y.: 2016-17 Shri Naval Seth Vs ACIT (L/H Late Sh. Ghansham Dass Circle-28(1) Seth) Civic Centre, Delhi M-90, Greater Kailash-I Delhi-48 (APPELLANT) (RESPONDENT) PAN No. AQOPS6274N Assessee by : Ms. Mansi Jain, Adv; Shri Sidharth Bajaj, Adv; Shri Tanishq Ahuja, Adv. Revenue by : Shri Ajay Kumar Arora, Sr. DR Date of Hearing: 06.01.2026 Date of Pronouncement: 06.01.2026 ORD…

Swami Vivekanand College, Thane vs. Income Tax Officer, WD-4(4), Thane

In the result, the appeal is allowed

ITA 6628/MUM/2025[2015-16]Status: DisposedITAT Mumbai05 Jan 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Jagadishswami Vivekanand College Income Tax Officer, Ward-4(4) Asher It Park, 6Th Floor, B-906 Cluster 3, Mira Road (E), Mira Road S.O., Near Midc, Road No. 16 Z, Vs. Thane-401 107 Wagle Industrial Estate, Thane-400 604 Pan/Gir No. Aaets 9320 H (Appellant) : (Respondent) Appellant By : Shri Prakash G. Jhunjhunwala & Shri Saiprasad Ghosh Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 17.12.2025 Date Of Pronouncement : 05.01.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against Order Dated 09.09.2025 Of National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2015-16. 2. In Ground No. 1, The Assessee Has Challenged The Validity Of Notice Issued U/S. 148 Of The Act, Being Barred By Limitation. Identical Issue Has Been Raised By The Assessee Through An Additional Ground Filed On 12.12.2025. Since, The Issue Raised By The Assessee Is A Purely Legal & Jurisdictional Issue Going To The Root Of The Matter & Can Be Decided Based On The Facts Available On Record, We Are Inclined To Admit The Additional Ground For Adjudication & Proceed To Decide It At The Very Outset.

For Appellant: Shri Prakash G. Jhunjhunwala &For Respondent: Shri Arun Kanti Datta – CIT DR

Section 139(1)Section 147Section 148Section 148A

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT AND SHRI JAGADISH, ACCOUNTANT MEMBER Swami Vivekanand College Income Tax Officer, Ward-4(4) Asher IT Park, 6th Floor, B-906 Cluster 3, Mira Road (E), Mira Road S.O., Near MIDC, Road No. 16 Z, Vs. Thane-401 107 Wagle Industrial Estate, Thane-400 604 PAN/GIR No. AAETS 9320 H (Appellant) : (Respondent) Appellant by : Shri Prakash G. Jhunjhunwala & Shri Saiprasad Ghosh Respondent by : Shri Arun Kanti Datta – CIT DR Date of Hearing : 17.12.2025 Date of Pronouncement : 05.01.2026 O R D E R Per Saktijit Dey, Vice President: T…

Damanjeet Singh Oberoi, Raipur vs. DCIT, Circle-1(1), Raipur

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

ITA 317/RPR/2025[2015-16]Status: DisposedITAT Raipur01 Jan 2026AY 2015-16

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Damanjeet Singh Oberoi Dcit, Circle 1(1), Raipur C/O Oberoi Tour & Travels, Shop No.1, Wali Mohd. Vs. Building, Kk Road, Moudhapara, Raipur – 492001 Pan: Aaepo3096L (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 133ASection 147Section 148Section 148ASection 69A

…Assessing Officer issued reopening notice to assessee for assessment year 2015-16 on 5-4-2022, since revenue had categorically made a concession before Hon’ble Supreme Court in case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/ 301 Taxman 238/ 469 ITR 46 (SC) that for assessment year 2015-16 it would drop all notices issued under section 148 after 1-4-2021, impugned notice dated 5-4-2022 and all consequential orders/notices would not survive. He submitted that since admittedly the notice u/s 148 of the Act was issued under the old regime on 30.06.2021 and thereafter under the new regime notice u/s…

Income Tax Officer-1(2), Raipur vs. Kanha Grain Process, Raipur

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

ITA 260/RPR/2025[2015-16]Status: DisposedITAT Raipur01 Jan 2026AY 2015-16

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Ito, Ward 1(2), Raipur Kanha Grain Process Vs. Station Road, Tilda Neora, Raipur – 493114 Pan: Aaifk3222G (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(3)Section 147Section 148Section 148ASection 69C

…ere the Assessing Officer issued reopening notice to assessee for assessment year 2015-16 on 5-4-2022, since revenue had categorically made a concession before Supreme Court in case of Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/ 301 Taxman 238/ 469 ITR 46 (SC) that for assessment year 2015-16 it would drop all notices issued under section 148 after 5 1-4-2021, impugned notice dated 5-4-2022 and all consequential orders/notices would not survive. He submitted that since admittedly the notice u/s 148 of the Act was issued under the old regime on 30.06.2021 and thereafter under the new regime notice…

Deputy Commissioner of Income Tax (Central Circle)-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1563/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

…of “Ashish Agrawal (supra)”, the notice u/s.148 of the Act, in this case, was issued on 30/08/2022. The Ld. Counsel has further submitted that this issue was also dealt with by the Hon’ble Supreme Court in the case of “Union of India vs. Rajeev Bansal (2024) 469 ITR 46 (SC)” and the Revenue therein, had conceded to the effect that so far as AY 2015-16 is concerned, the Revenue could not have issued the notices u/s.3(1) of “Taxation and other laws” (Relaxation of certain provisions) Ordinance, 2020 (in short, “TOLA”) as considering the time period as prescribed u/s.149 of the Act, with effect from 01.04.2021, thr…

Deputy Commissioner of Income Tax, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1562/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

DCIT, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1451/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

DCIT, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1450/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR

Section 147Section 148Section 148ASection 149Section 250Section 3(1)

Karnataka Telecom Department Employees Co-Operative Society Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle 1(4), Blr, Bangalore

In the result, appeals of Revenue in ITA Nos

ITA 1080/BANG/2025[2016-17]Status: DisposedITAT Bangalore31 Dec 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Years: 2016-17

For Appellant: Shri PR Suresh, CAFor Respondent: Shri N Balusamy, JCIT-DR

Section 143(3)Section 147Section 148Section 148ASection 149Section 250Section 80(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment Years: 2016-17 Karnataka Telecom Department Employees Co-operative Society Limited, The Deputy No.106, 2nd Block, P & T Colony, Commissioner of Income RT Nagar, Bangalore North, Tax, P &T Col., Kavalbyrasandra S.O, Central Circle – 1(4), Bangalore – 560 032. Bengaluru. Vs. PAN : AAAAK 6096 K APPELLANT RESPONDENT Assessee by : Shri PR Suresh, CA Revenue by : Shri N Balusamy, JCIT-DR Date of Hearing : 10-12-2025 Date of Pronouncement : 31-12-2025 ORDER PER…

Assistant Commissioner of Income Tax, Mumbai vs. Surbhi Jewellers Private Limited, Mumbai

In the result, appeal filed by revenue stands dismissed

ITA 5447/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 148ASection 151Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI JAGADISH (ACCOUNTANT MEMBER) I.T.A. No. 5447/Mum/2025 Assessment Year: 2017-18 Assistant Commissioner Vs. Surbhi Jewellers Private of Income Tax Limited Shop No. 1, Parekh Market MG Road Ghatkopar E Mumbai - 400077 [PAN: AABCS1062Q] (Appellant) (Respondent) Assessee by Shri Khushali Desai Revenue by Shri Arun Kanti Dalla, CIT DR Date of Hearing 16.12.2025 Date of Pronouncement 31.12.2025 ORDER Per Smt. Beena Pillai, JM: Present appeal filed by revenue arises out of order dated 20/06/2025 passed by NFAC - New…

Mr Vinay Narayan Kedia, Mumbai vs. Income Tax Officer, Ward 22(3)(6), Mumbai

In the result, appeal filed by assessee stands allowed

ITA 5289/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 10(38)Section 147Section 148Section 148BSection 151Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI MAKARAND VASANT MAHADEOKAR (ACCOUNTANT MEMBER) I.T.A. No. 5289/Mum/2024 Assessment Year: 2015-16 Mr. Vinay Narayan Kedia Vs. Income Tax Officer, Ward- 13, Utkarsh, J.A. Rahul Road Prabha Devi Mumbai - 400025 [PAN: AGDPK6666R] (Appellant) 22(3)(6), Mumbai (Respondent) Assessee by | Shri Rajiv Khandelwal, A/R Revenue by Ms. Kavitha Kaushik, Sr. D/R Date of Hearing 09.12.2025 Date of Pronouncement 31.12.2025 ORDER Per Smt. Beena Pillai, JM: Present appeal filed by assessee arises out of order dated 23/08/2025 pa…

Anuj Kapoor, New Delhi vs. DCIT Circle-16(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 4098/DEL/2025[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh

Section 147Section 148Section 148ASection 68Section 69A

…e filed an additional ground of appeal challenging the notice dated 21.07.2022 issued u/s 148 of the Act, on the ground that it was barred by limitation in the light of the decision of the Hon’ble Supreme Court in the case of Union of India vs. Rajeev Bansal (469 ITR 46). In this regard, the letter dated 14.10.2025 of the assessee for filing of the additional ground is reproduced as under: “It is respectfully stated that the assessee wishes to raise the following ground of appeal, as additional grounds of appeal: A. On the peculiar facts of the case, the notice dt.21.07.2022 issued u/s 148 is barred by limitatio…