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“reassessment proceedings”

ReassessmentSections 147-151Sections 147-1518,150 judgments

The decision most relied on for reassessment proceedings is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on reassessment proceedings

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

ITO v. Lakhmani Mewal Das
103 ITR 437 · 1976 · Supreme Court
721
citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

PCIT v. Meenakshi Overseas Pvt. Ltd.
395 ITR 677 · 2017 · High Court
471
citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Ranbaxy Laboratories Ltd. v. CIT
336 ITR 136 · 2011 · High Court
398
citing judgments

In reassessment proceedings under Section 147/148, the Assessing Officer can assess other income not specified in the original notice if the initial ground for reopening assessment is found to be valid. However, if the income for which the assessment was initially reopened is found not to have escaped assessment, the Assessing Officer cannot proceed to assess any other income.

Judgments citing reassessment proceedings

Amrit Corporation, Mumbai vs. DCIT-CC-1(1), Mumbai

ITA 1660/MUM/2025[2020-2021]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-2021

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Aditya M. RaiFor Respondent: Shri Jayant Bhatt
Section 148Section 69C

principles of natural justice for affording an opportunity to the appellant to cross examine the alleged evidences collated and relied upon in the reassessment proceedings. 5. The appellant craves right to alter, amend, withdraw or substitute any ground or grounds or to add any new ground or grounds of appeal

Amrit Corporation, Mumbai vs. DCIT-CC-1(1), Mumbai

ITA 1659/MUM/2025[2019-2020]Status: DisposedITAT Mumbai06 Oct 2025AY 2019-2020

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am)

For Appellant: Shri Aditya M. RaiFor Respondent: Shri Jayant Bhatt
Section 148Section 69C

principles of natural justice for affording an opportunity to the appellant to cross examine the alleged evidences collated and relied upon in the reassessment proceedings. 5. The appellant craves right to alter, amend, withdraw or substitute any ground or grounds or to add any new ground or grounds of appeal

Tigerhill Tradelink Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the Appellant is Dismissed

ITA 956/KOL/2025[2014-2015]Status: DisposedITAT Kolkata03 Oct 2025AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 250Section 271BSection 68

wholly illegal, arbitrary, and without jurisdiction. The Hon'ble Supreme Court in Rajeev Bansal & Ors. v. Union of India has categorically held that reassessment proceedings initiated beyond the prescribed time limit are barred by limitation. In the present case, the reassessment is time-barred and suffers from jurisdictional defects, rendering ... Assessment Centre (NFAC). In the present case, the failure to adhere to this prescribed procedure renders the notice legally unsustainable and vitiates the entire reassessment proceedings, making them null and void. 3. That the notice issued under Section 148 of the Act, dated 30-07-2022, was issued manually without

Tigerhill Tradelink Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the Appellant is Dismissed

ITA 955/KOL/2025[2014-2015]Status: DisposedITAT Kolkata03 Oct 2025AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 250Section 271BSection 68

wholly illegal, arbitrary, and without jurisdiction. The Hon'ble Supreme Court in Rajeev Bansal & Ors. v. Union of India has categorically held that reassessment proceedings initiated beyond the prescribed time limit are barred by limitation. In the present case, the reassessment is time-barred and suffers from jurisdictional defects, rendering ... Assessment Centre (NFAC). In the present case, the failure to adhere to this prescribed procedure renders the notice legally unsustainable and vitiates the entire reassessment proceedings, making them null and void. 3. That the notice issued under Section 148 of the Act, dated 30-07-2022, was issued manually without

Garje Rudrappa Jayanna, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result, appeals filed by the assessee are partly allowed

ITA 1079/BANG/2025[2018-19]Status: DisposedITAT Bangalore03 Oct 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 147Section 148Section 148ASection 149Section 271F

huge cash was deposited in his bank account in spite of that assessee did not file return of income. Even during the course of reassessment proceedings, various opportunities were given to the assessee. The AO has initiated penalty proceedings under section 271F of the Act for not filing income ... section 149(1)(b) of the Act, income of the assessee is less than 50 lakhs as assessed by the AO in the reassessment proceedings under section ITA Nos.1078, 1079/Bang/2025 Page 12 of 17 147 r.w.s. 144B of the Act. Therefore, the period of more than thre years

Garje Rudrappa Jayanna, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result, appeals filed by the assessee are partly allowed

ITA 1078/BANG/2025[2015-16]Status: DisposedITAT Bangalore03 Oct 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 147Section 148Section 148ASection 149Section 271F

huge cash was deposited in his bank account in spite of that assessee did not file return of income. Even during the course of reassessment proceedings, various opportunities were given to the assessee. The AO has initiated penalty proceedings under section 271F of the Act for not filing income ... section 149(1)(b) of the Act, income of the assessee is less than 50 lakhs as assessed by the AO in the reassessment proceedings under section ITA Nos.1078, 1079/Bang/2025 Page 12 of 17 147 r.w.s. 144B of the Act. Therefore, the period of more than thre years

Krishna Devi Sehrawat, Delhi vs. ITO Ward-43(6), Delhi

In the result, the appeal of the assessee is dismissed in the

ITA 3359/DEL/2025[2017-18]Status: DisposedITAT Delhi03 Oct 2025AY 2017-18

Bench: Sh. Sudhir Kumar

Section 142(1)Section 144Section 147Section 148Section 148ASection 151ASection 251(1)(a)Section 69A

quashed and CIT(A) erred in not holding so. ti) On the facts and circumstances of the case and in law, the reassessment proceedings initiated are contrary to the provisions of law including the specific provisions of section 147 to section 151A of the Income Tax Act, 1961 and therefore ... reassessment proceeding initiated alognwith the assessment order passed are liable to be quashed and CIT(A) erred in not holding so. iii) On the facts and circumstances of the case and in law, the assessment order passed by the AO is bad in law, without jurisdiction and barred by limitation

Jitendra Singh, Bijnor vs. Income Tax Officer, Bijnor

In the result, the Assessee’s appeal is allowed

ITA 3316/DEL/2025[2015-16]Status: DisposedITAT Delhi03 Oct 2025AY 2015-16

Bench: Shri Mahavir Singhasstt. Year : 2015-16 Jitendra Singh, Vs. Acit/Jcit(Appeals) C/O S R Agarwalla & Co., Ca Faridabad / Nfac Shop No. 7, Kisan Inter College Market, Meerut-Karnal Road, Shamli, Uttar Pradesh-246776 (Pan: Ezaps4872M) (Appellant) (Respondent) Appellant By : Sh. Manish Singh, Ca Respondent By : Ms. Harpreet Kaur Hansra, Sr. Dr. Date Of Hearing 09.09.2025 Date Of Pronouncement 03.10.2025 Order This Appeal By The Assessee Is Emanating From The Order Of The Ld. Addl/Jcit (A), Faridabad Dated 27.03.2025 Pertaining To Assessment Year 2015-16 On The Solitary Issue Of Addition Of Rs. 13,00,000/- On Account Of Cash Deposit. 2. Heard Both The Sides & Perused The Records. 3. Brief Facts Of The Case Are That The Information Reported In Aims Module Of Itba That The Assessee Had Deposited More Than Rs. 10 Lacs In Different Saving Bank Accounts Maintained By Him During The F.Y. 2014-15 Relevant To Ay 2015-16. A Query Letter As Well As A Notice U/S. 133(6) Of The Income Tax Act, 1961 Was Issued & Served Upon The Assessee Asking Him To Furnish The Source Of Income & Credit

For Appellant: Sh. Manish Singh, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 133(6)Section 147Section 69A

assessee failed to furnish any satisfactory explanation. Further no return of income was filed by the assessee for the year under consideration. Accordingly, reassessment proceedings were initiated in the case of the assessee. During the course of reassessment proceedings, the appellant was asked to furnish details and source of cash ... deposits are directly linked between date of agreement to sell and sale deed. No cash was deposited after the sale deed. The AO initiated reassessment proceedings under Section 147 of the Act, alleging escapement of income based on information regarding cash deposits in the Appellant's bank account

Takdir Traders, Rajkot vs. The PCIT-1, Rajkot

In the result, the appeal filed by the assessee is dismissed”

ITA 383/RJT/2024[2015-16]Status: DisposedITAT Rajkot01 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT DR
Section 147Section 263

that the observation made by the Ld.PCIT is not correct at all, because of the fact that the Faceless Unit in the course of reassessment proceeding issued Notice u/s 142(1) of the Income Tax Act 1961 dated 20.01.2022 wherein the FAO specifically raised the query in form of questionnaire ... financial transaction entered into with National Shroff and the assessment was completed by the AO after making necessary enquiry during the course of reassessment proceeding, 11. The Ld.PCIT has consider the submission made by the assessee and observed that: Takdir Trader v. PCIT “It is the bounden duty

Takdir Traders, Rajkot vs. The PCIT-1, Rajkot

In the result, the appeal filed by the assessee is dismissed”

ITA 380/RJT/2024[2014-15]Status: DisposedITAT Rajkot01 Oct 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT DR
Section 147Section 263

that the observation made by the Ld.PCIT is not correct at all, because of the fact that the Faceless Unit in the course of reassessment proceeding issued Notice u/s 142(1) of the Income Tax Act 1961 dated 20.01.2022 wherein the FAO specifically raised the query in form of questionnaire ... financial transaction entered into with National Shroff and the assessment was completed by the AO after making necessary enquiry during the course of reassessment proceeding, 11. The Ld.PCIT has consider the submission made by the assessee and observed that: Takdir Trader v. PCIT “It is the bounden duty

Takdir Traders, Rajkot vs. The PCIT-1, Rajkot

In the result, the appeal filed by the assessee is dismissed”

ITA 378/RJT/2024[2013-14]Status: DisposedITAT Rajkot01 Oct 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT DR
Section 147Section 263

that the observation made by the Ld.PCIT is not correct at all, because of the fact that the Faceless Unit in the course of reassessment proceeding issued Notice u/s 142(1) of the Income Tax Act 1961 dated 20.01.2022 wherein the FAO specifically raised the query in form of questionnaire ... financial transaction entered into with National Shroff and the assessment was completed by the AO after making necessary enquiry during the course of reassessment proceeding, 11. The Ld.PCIT has consider the submission made by the assessee and observed that: Takdir Trader v. PCIT “It is the bounden duty

Late Shri Jitendra Nagar Through His L/R Smt. Deepika Nagar, Baran vs. Income Tax Officer Ward Baran, Baran

In the result, appeal of the assessee is allowed

ITA 1382/JPR/2024[2016-2017]Status: DisposedITAT Jaipur01 Oct 2025AY 2016-2017

Bench: The Date Of Hearing.”

For Appellant: Shri Sidharth Ranka, AdvFor Respondent: Shri. Gautam Singh Choudhary, JCIT a
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 250Section 69A

Jewellery[2025] 4 TMI 393 dated 24.03.2025 after considering the aforesaid judgment of Hon’ble Supreme Court in Rajeev Bansal (supra) has held: Reassessment proceedings - validity of approval granted u/s 151(i) - HELD THAT:- Admittedly the assessment was reopened after elapsing of three years from the end of the relevant ... issue a notice under Section 148 of the Act. Accordingly, the order, dated 30/07/2022 passed under Section 148A(d) of the Act, the consequential reassessment proceedings and the order, dated 25/05/2023, passed under Section 147 read with Section 144B of the Act are quashed as bad in law being

Pelican Tobacco India Private Limited vs. ITO, Ward - 19(4), New Delhi

Appeal is allowed

ITA 129/DEL/2024[2012-13]Status: DisposedITAT Delhi01 Oct 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. Avdhesh Kumar Mishra

For Appellant: Sh. Udit Dad, AdvFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(2)Section 147Section 148Section 2

served upon the assessee. 4.1.3 The appellant in a submission mentioned that a notice u/s 143(2) was not issued during the course of reassessment proceedings. However, as per the Assessing Officer in the assessment order, a notice u/s 143(2) of Income Tax Act dated 23.10.2019 was issued ... Pelican Tobacco India Pvt. Ltd. during the course of reassessment proceedings. Similarly, in the paper book filed before the undersigned the appellant did not file a copy of return filed in response to the notice u/s 148 of Income Tax Act. The appellant in its submission mentioned that the Assessee

Shervani Sugar Syndicate Limited, Ghaziabad vs. Dc/ACIT-2, Allahabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 138/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2012-13 Shervani Sugar Syndicate V. National Faceless Limited Assessment Centre 17, Navyug Market, Ghaziabad- Delhi. 201001. Pan:Aadcs3658L (Appellant) (Respondent) Assessment Year: 2012-13 Shervani Sugar Syndicate V. Dc/Acit-2, Allahabad Limited Office Of The Assistant C/O 17, Navyug Market, Commissioner Of Income Ghaziabad-201001. Tax, Allahabad, Allahabad-211001. Pan:Aadcs3658L (Appellant) (Respondent) Appellant By: Shri Madhav Kapur Respondent By: Shri A. K. Singh, Sr. Dr Date Of Hearing: 23 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

For Appellant: Shri Madhav KapurFor Respondent: Shri A. K. Singh, Sr. DR
Section 147Section 253(3)

without appreciating the fact, that the reasons recorded for the impugned re-opening are based non-existent facts. Thus, makes the entire reassessment proceedings void ab inito. 4. That the Ld. CIT(A) has erred in law and on facts of the case in confirming the action

Shervani Sugar Syndicate Limited, C/O B. K. Kapur Co vs. National Faceless Assessment Centre, Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 137/ALLD/2025[2012-13]Status: DisposedITAT Allahabad30 Sept 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguriaassessment Year: 2012-13 Shervani Sugar Syndicate V. National Faceless Limited Assessment Centre 17, Navyug Market, Ghaziabad- Delhi. 201001. Pan:Aadcs3658L (Appellant) (Respondent) Assessment Year: 2012-13 Shervani Sugar Syndicate V. Dc/Acit-2, Allahabad Limited Office Of The Assistant C/O 17, Navyug Market, Commissioner Of Income Ghaziabad-201001. Tax, Allahabad, Allahabad-211001. Pan:Aadcs3658L (Appellant) (Respondent) Appellant By: Shri Madhav Kapur Respondent By: Shri A. K. Singh, Sr. Dr Date Of Hearing: 23 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

For Appellant: Shri Madhav KapurFor Respondent: Shri A. K. Singh, Sr. DR
Section 147Section 253(3)

without appreciating the fact, that the reasons recorded for the impugned re-opening are based non-existent facts. Thus, makes the entire reassessment proceedings void ab inito. 4. That the Ld. CIT(A) has erred in law and on facts of the case in confirming the action

Shri Sanjay Gordhandas Vaja, Ahmedabad vs. The ITO, International Taxation, Gandhidham-Kutch

In the result, this appeal of the assessee is allowed

ITA 89/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Sept 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.89/Rjt/2024 Assessment Year: 2018-19 Sanjay Gordhandas Vaja Income Tax Officer Int. 202, Harmony Heights, Capital Road, बनाम Tax), Gandhidham, Income- Science City, Ahmedabad-380 060 Tax Office, Amruta Estate /Vs. Building, Nr. Girnar Cinema, M.G. Road, Rajkot-360 001 "थायीलेखासं /.जीआइआरसं . / Pan/Gir No.: Ahtpv 3289 L (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Aseem Takkar, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 31/07/2025 घोषणा क" तार"ख /Date Of Pronouncement : 30/09/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2018-19, Is Directed Against The Final Order Passed By The Assessing Officer, (After Incorporating Findings Of Dispute Resolution Panel-2 Mumbai, Dated 29.12.2023), Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) .

For Appellant: Shri Aseem Takkar, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 115BSection 144CSection 147Section 148Section 148ASection 68Section 69

however not disclosed the transactions by filing the return of income within the time provided u/s 139(1) of the Act. During the reassessment proceedings, the assessee had furnished detailed explanation in response to the notice issued u/s 142(1) of the Act. The AO has reproduced the submission dated

Jitendrabhai Bhagvanbhai Dalvadi, Surendranagar vs. ITO Ward 2, Morbi

In the result, the appeal of the assessee is allowed

ITA 466/RJT/2024[2011-12]Status: DisposedITAT Rajkot30 Sept 2025AY 2011-12

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 124Section 127Section 143(3)Section 147Section 234ASection 250Section 254Section 271(1)(c)Section 68

that assessee cannot raise these legal issue first time before the Tribunal. Since the additional grounds raised by the assessee challenging the validity of reassessment proceedings is a legal issue which goes to the root of the matter and no further inquiry is needed for deciding the said legal issue ... outset submitted that during assessment proceedings, the reopening of assessment was carried out without obtaining prior approval from higher authority. That is reassessment proceedings were initiated under section 148/147 of the Act, without taking permission from the prescribed authority, hence reopening of assessment should be quashed on this score only

Nimmana Narasimharao, Eluru vs. Income Tax Officer, Ward-2, Eluru

ITA 50/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2017-18

Bench: Us:

Section 133(6)Section 142(1)Section 143(2)Section 144Section 155BSection 69A

held that where the A.O did not issue notice u/s.143(2) of the Act upon the assessee, then the initiation of reassessment proceedings; order rejecting the assessee’s objection against the assumption of jurisdiction for reopening and also the reference to the TPO were to be quashed. 21. Apropos

Deputy Commissioner of Income Tax (It), Visakhapatnam vs. Shri Apparao Mukkamala, Usa

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

ITA 354/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

Section 144C(3)Section 147Section 148Section 153CSection 69A

treated as having been filed in response to the notice issued under Section 148 of the Act. 6. During the course of the reassessment proceedings, the A.O. confronted the assessee with the seized handwritten scribbling. In reply, the assessee denied receipt of any cash consideration. In fact, the assessee ... have considered the rival submissions and perused the record. Admittedly, it is a matter of fact borne from record that the impugned reassessment proceedings in the case of the assessee were initiated based on the handwritten scribblings that were found and seized during the course of the search proceedings conducted

Gandem Nageswara Rao, Visakhapatnam vs. Income Tax Officer, Ward-1, Anakapalle

ITA 304/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2016-17
Section 144Section 147Section 148Section 148ASection 151ASection 69A

gave only 06 days of time to the appellant, which is less than the stipulated period of 07 clear days and consequently the entire reassessment proceedings are liable to be quashed as void-ab-initio. 2. The notice issued U/s. 148 of the Act on 16/03/2023 by the jurisdictional Assessing