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“income escaping assessment”

ReassessmentSection 147Section 1471,518 judgments

HIMANSHU DAKSHESHKUMAR KATWALA,KHAMBHAT ANAND vs. INCOME TAX OFFICER, WARD-1(3)(1), PETLAD

In the result, the appeal of the assessee is allowed

ITA 199/AHD/2026[2017-2018]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2017-2018

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Hardik J Raval & Vivek D Rao, ARsFor Respondent: Shri Girish Parihar, Sr. DR
Section 115BSection 132Section 143(3)Section 147Section 69A

namely Shri Jignesh Shah and Shri Sanjay Shah. However, the Assessing Officer has failed to identify and specify the exact nature of alleged income escaping assessment in the hands of the assessee. The reasons recorded merely state that the assessee has entered into transactions ... initiated without proper application of mind and without even identifying the precise nature of HImanshu Daksheshkumar Katwala vs. ITO Asst.Year –2017-18 - 6– income escaping assessment. The initiation of proceedings under section 147 is therefore bad in law and liable to be quashed. 13. Since the very foundation of reassessment

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

ITA 5011/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Mar 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

Section 144Section 144BSection 147Section 148Section 194CSection 194ISection 234FSection 250

Court in Hexaware Technologies Ltd. v. ACIT (162taxmann.com225), wherein the Court examined the scheme framed under section 151A and the E-Assessment of Income Escaping Assessment Scheme, 2022. The Hon’ble Bombay High Court held, inter alia, that once the scheme mandates issuance of notice under section 148 through automated

SHRI PARASRAM COMMODITIES PVT LTD.,DELHI vs. DCIT, CIRCLE-23(1), DELHI

In the result the appeal of the assessee is allowed

ITA 4630/DEL/2025[2012-13]Status: DisposedITAT Delhi18 Mar 2026AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 68

Educational Society [2017]79 taxmann.com 43(Delhi) the Hon’ble Delhi High court held that section 147 of the Income Tax Act, 1961-income escaping assessment –Non disclosure of primary facts (scope of assessment) –Assessment year 2003-4 –If no addition is made in respect of issues recorded by Assessing

RUPINDER SINGH DUGGAL,AHMEDABAD vs. THE ITO, WARD-5(3)(2), AHMEDABAD

In the result the appeal filed by the assessee is allowed

ITA 1921/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 149Section 151Section 192Section 54Section 80C

Officer instead of the National Faceless Assessment Centre (NFAC) is without jurisdiction, being contrary to the procedure prescribed under the E- Assessment of Income Escaping Assessment Scheme, 2022, notified vide CBDT Notification No. 18/2022 dated 29.03.2022. 4. Without prejudice to forgoing grounds, (A) The learned Commissioner of Income-tax (Appeals

BMR OVERSEAS LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(2), C.R. BUILDING DELHI 110002, DELHI

In the result the appeal of the assessee is allowed

ITA 6646/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Bmr Overseas Limited, Vs. Dcit, Circle 4(2), Zb-33/487, Plot No. 4 & 5, C.R. Building, Dilshad Garde New Delhi Industrial Area, Shahdara, Delhi – 110 095 [Pan No. Aafcb8509D) (Appellant) (Respondent)

Section 115BSection 143Section 147Section 148Section 151Section 156Section 157ASection 68

directly co-related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval ... appropriate authorities specified under Section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

KASHI NATH SETH SARRAF PRIVATE LIMITED,HARDOI vs. DCIT, SITAPUR, SITAPUR

In the result, the appeal of the assessee stands allowed for\nstatistical purposes

ITA 86/LKW/2024[2012-13]Status: DisposedITAT Lucknow12 Mar 2026AY 2012-13
For Respondent: \nShri Akshay Agrawal, Advocate
Section 142(1)Section 143(3)Section 147Section 148Section 151Section 68

first proviso to section 147 of the Act\ndeserves acceptance. Section 147 of the Act is the relevant\nprovision of law for assessing income escaping assessment. As\nnoted earlier, in this case notice u/s 148 r.w.s.147 of the Act\ndated 30.08.2019 was issued to the assessee resulting in\naforesaid assessment

BETHANY MENNONITE BRETHREN CHURCH,MAHABUBNAGAR vs. ITO, WARD-1, MAHABUBNAGAR

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

ITA 2012/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.2012/Hyd/2025 Assessment Year 2016-2017 Bethany Mennonite The Income Tax Officer, Brethren Church, Ward-1, Vs. Mahabubnagar - 509301. Mahabubnagar. Telangana. Telangana. Pan Aacab3321J (Applicant) (Respondent) िनधा"रती "ारा/Assessee By : Sri S Rama Rao, Advocate राज" व "ारा/Revenue By : Sri Mathivanan S A, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 05.03.2026 घोषणा की तारीख/Pronouncement: 11.03.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri S Rama Rao, AdvocateFor Respondent: Sri Mathivanan S A, Sr. AR
Section 148Section 148A

learned CIT (A) ought to have considered the fact that the initiation of proceedings u/s 148 is not justified as the income escaping assessment is less than Rs.50 lakhs and more than 3 years expired after the end of the previous year; 5) The learned CIT (A) ought to have

DCIT., CIRCLE-2(1), HYDRABAD vs. KALPTARU INVESTMENTS PRIVATE LIMITED, HYDERABAD

In the result, appeal ITA

ITA 1077/HYD/2025[2013-14]Status: DisposedITAT Hyderabad11 Mar 2026AY 2013-14
For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 147

order is liable to be\nquashed.\n(ii) For that on the facts and in the circumstances of the\ncase, there was no income escaping assessment in as\nmuch as the impugned sum set out in the recorded\nreasons was already forming part of the taxable income\nand there ... n20.03.2020 which is after 04 years from the end of the\n assessment year under consideration. The Assessing Officer\nproposed to assess the income escaped assessment on\naccount of the profit earned by the assessee on derivative\ntransactions of Rs.1,49,86,825/- on the belief that the\nassessee

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

In the result, the appeal of the assessee is allowed in above terms

ITA 2499/DEL/2025[2013-14]Status: DisposedITAT Delhi11 Mar 2026AY 2013-14
For Appellant: Sh. M.R. Sahu, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 144Section 147Section 148Section 148(1)

regarding the\nservice of the notice upon the assessee. Section 148(1) clearly reflects that in\norder to fulfil the jurisdictional requirement for income escaped assessment\nproceedings u/s.147. It was further submitted that in the present case\npreliminary jurisdictional notice u/s.148 and other notices are just reflected in\nthe ... mere procedural\nrequirement but is a condition precedent to the validity of any reassessment\nmade. Mere issuance of notice for income escaping assessment is not sufficient\nbut its service on the assessee, that too, within the time frame envisaged under\nsection 149 of the Act is necessary for a valid

EAST DELHI LEASING P.LTD,NEW DELHI vs. ITO, WARD-8(1), NEW DELHI

In the result, appeal filed by the assessee is allowed

ITA 7917/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11
Section 142(1)Section 147Section 148

purpose of the section.\nTo this limited extent, the action of the Income Tax Officer in starting\nproceedings in respect of income escaping assessment is open to\nchallenge in a court of law\"\nThe aforesaid principle has been followed by the Hon'ble Supreme Court\nin Deputy Commissioner of Income

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

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

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

Gobarji Seva Sansthan ILOL vs. ITO [2025] 172 taxmann.com 89 (Gujarat) Section 148A, read with section 147, of the Income-tax Act, 1961 - Income escaping assessment Conducting inquiry, providing opportunity before issue of notice under section 148 (General) - Assessment year 2019-20 - Assessee-trust did not file return of income ... note that section 151 of the Act, mandates prior approval of the "specified authority" before issuing a notice under Section 148 for income escaping assessment. If the document granting approval lacks a manual or digital signature, it calls into question the authority's satisfaction. Physical signature is the traditional evidence

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

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

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

Gobarji Seva Sansthan ILOL vs. ITO [2025] 172 taxmann.com 89 (Gujarat) Section 148A, read with section 147, of the Income-tax Act, 1961 - Income escaping assessment Conducting inquiry, providing opportunity before issue of notice under section 148 (General) - Assessment year 2019-20 - Assessee-trust did not file return of income ... note that section 151 of the Act, mandates prior approval of the "specified authority" before issuing a notice under Section 148 for income escaping assessment. If the document granting approval lacks a manual or digital signature, it calls into question the authority's satisfaction. Physical signature is the traditional evidence

INFINITY INTERNATIONAL,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, appeal of the assessee is dismissed

ITA 518/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147Section 148Section 153(3)Section 250Section 68

proceedings initiated by Your Goodself may be dropped in the larger interest of justice. 4.7 "NO CAUSE AND EFFECT RELATIONSHIP" BETWEEN "REASONS RECORDED" & "INCOME ESCAPING ASSESSMENT": 4.7.1 The assessee further submits that it is important to bear in mind the subtle but important distinction between "factors which indicate an income ... escaping assessment" and "factors which indicate a suspicion about income escaping assessment". The former category consists of facts which, if established to be correct, will have a cause and effect relationship within income escaping assessment. The latter category consists of facts which, if established to be correct, could legitimately lead

KALPANA SANJAY PAWAR,MUMBAI vs. ITO WD-41(1)(2), MUMBAI

ITA 9047/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Mar 2026AY 2017-18

Bench: the Tribunal challenging the validity of the re-assessment proceedings raising, inter alia, the following grounds: "2. On the facts and circumstances of the case and in law, the learned Assessing Officer has erred in issuing the order under Section 148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-1, Mumbai which was not the correct 'specified authority' as per Section 151 who should have approved it when three years have already elapsed from the

For Appellant: Shri Aditya RamachandranFor Respondent: Ms. Deepika Arora
Section 1Section 144BSection 147Section 148Section 148ASection 151Section 151A

having the jurisdiction for the same in view of Section 151A and the notification issued there under notifying e-Assessment of Income Escaping Assessment Scheme, 2022 and, thereby, rendering the said order and the notice as well as the entire assessment 2 Assessment Year 2017-2018 proceeding as null ... directly co-related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be issued under Section 148 within four years after obtaining the approval

SUDHIR DAMJI BHARANI,MUMBAI vs. ITO WD-27(3)(1), NAVI MUMBAI

ITA 9046/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Mar 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Aditya RamachandranFor Respondent: Ms. Deepika Arora
Section 144BSection 147Section 148Section 148ASection 149Section 151

directly co-related to the time when the notice is issued. This plays out as follows under the old regime: (i) If income escaping assessment was less than Rupees one lakh: (a) a reassessment notice could be 4 Assessment Year 2017-2018 issued under Section 148 within four years after ... appropriate authorities specified under section 151 of the new regime. The effect of Section 151 of the new regime is thus: (i) If income escaping assessment is less than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal

SURESH KUMAR PODDAR,KOLKATA vs. I.T.O., WARD - 63(4), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

ITA 1542/KOL/2024[2011-2012]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-2012

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 111ASection 132Section 132(1)Section 139(1)Section 144Section 147Section 148Section 153CSection 250Section 250o

provisions of Section 147 of the IT. Act, it will be appropriate to extract the said provisions, which reads thus: "147. Income escaping assessment. If the Assessing Officer has reason tobelieve that any income chargeable to tax has escaped assessment for any assessment year, he may, subject to the provisions

DEEPAK MAHADEO BHOIR ,MUMBAI vs. INCOME TAX OFFICER WARD, 42(1)(2), MUMBAI

In the result, the appeal is allowed as indicated above

ITA 3597/MUM/2024[2013-14]Status: DisposedITAT Mumbai06 Mar 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardeepak Mahadeo Bhoir, Income Tax Officer, C/O Bharat Kumar, 317, Ward 42(1)(2), Prasad Chamber, Opera House, Vs. Mumbai - 400051 Mumbai – 400 004 (Appellant) : (Respondent) Pan No. Ajupb 7841H Appellant By : Shri Bharat Kumar, Ca Respondent By : Shri Annavaran Kosuri, Sr.- Dr (Appellant) (Respondent) Date Of Hearing : 12.02.2026 Date Of Pronouncement : 06.03.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Challenging The Order Dated 26.06.2024 Passed By National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year (A.Y.) 2013-14. 2. Before We Proceed To Decide The Substantive Issue Arising For Consideration, It Is Necessary To Provide A Brief Factual Background. This Appeal Was Earlier Disposed Of By The Coordinate Bench Vide Order Dated 12.12.2024. Subsequently, Assessee Filed A Miscellaneous Application Seeking Rectification/Recall Of The Appellate Order On The Ground That While Deciding The Appeal, The Bench Had Failed To Decide Ground No. 2.A & 2.B. While Deciding The Miscellaneous Application, The Bench Having Found Merit In The Submissions Of Assessee, Recalled The Order For The Limited Purpose Of Deciding Ground No. 2.A & 2.B Raised In The Memorandum Of Appeal. This Is How The Appeal Came Up For Hearing Before Us.

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Annavaran Kosuri, Sr.- DR
Section 147Section 148Section 148ASection 149

through the said judgement, we are of the view that the Hon'ble High Court has proceeded on the premise that since the income escaping assessment has exceeded Rs.50 lacs, the A.O. has 10 years time to reopen the assessment in terms with section 149 of the Act under

MAMATHA MAHESH SHETTY,CHIKKAMAGALURU vs. INCOME TAX OFFICER, WARD-1, CHIKMAGALUR

In the result, the appeal of the assessee is hereby partly allowed

ITA 2382/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: Shri Ravishankar S.V, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 250

only. Hence, a notice under section 148 of the Act was issued to the assessee to initiate income escaping assessment under section 147 of the Act. In response the assessee filed return of income declaring income at NIL. 10.1 Further the assessee during the assessment proceedings submitted that

JIGNESH NATVERLAL PATEL (REPRESNTED BY LATE NATVERLAL NANUBHAI PATEL),MUMBAI vs. ITO WARD 24(3)(1), MUMBAI

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

ITA 6769/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Mar 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawaljignesh Natverlal Patel Vs Ito Ward-24(3)(1), Mumbai (Represented By Late Piramal Chamber, Lalbaug, Natverlal Nanubhai Patel) Mumbai-400012 401 Adarsh Building, Rto Four Bunglows, Andheri (West), Mumbai-400053 Pan:Aaapp1767B Appellant Respondent

For Appellant: Shri Aditya RamchandranFor Respondent: Shri Sushil B. Shende (Sr DR)
Section 139(1)Section 147rSection 148Section 148ASection 149Section 151Section 151ASection 250

having the jurisdiction for the same in view of Section 151A and the notification issued thereunder notifying e-Assessment of Income Escaping Assessment Scheme, 2022 and, thereby. rendering the said order and the notice as well as the entire assessment proceeding as null and void. 4. On the facts

SRINIVASA RAO SIRIVURI PROPRIETOR,VIZIANAGARAM vs. INCOME TAX OFFICER, VIZIANAGARAM

In the result, appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 459/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam04 Mar 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 44ASection 69A

proviso to S.149(1) of the Act. b) Thirdly, the notice was issued by the JAO. After the introduction of 'E-Assessment of Income Escaping Assessment Scheme, 2022' w.e.f. 29.03.2022, the notice u/s 148 shall be issued in faceless manner by the FAO. However, the notice in the case

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