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“income escaping assessment”

ReassessmentSection 147Section 1471,518 judgments

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

Leading authorities on income escaping assessment

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.

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.

CIT v. Sun Engineering Works (P) Ltd.
198 ITR 297 · 1992 · Supreme Court
814
citing judgments

A court's pronouncement derives its scope and color from the specific questions involved in the case, thus, due regard must always be given to the questions framed before the court when interpreting its judgment.

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.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

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.

Judgments citing income escaping assessment

M/S. Rajeshwar Bullion Trading, Mumbai vs. Asst. CIT, Circle 23(3), Mumbai

In the result, the appeal is dismissed

ITA 5754/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)
Section 115BSection 147Section 68

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 ... Principal Director or Commissioner or Director; and (b) no notice could be issued after the expiry of three years; and (ii) If income escaping assessment is more than Rupees fifty lakhs: (a) a reassessment notice could be issued within three years after obtaining the prior approval of the Principal Commissioner

Ramjidas Budhraja Charitable Trust (Sgm), Chhindwara vs. Income Tax Officer Exemption, Jabalpur

In the result, the appeal of the assessee is dismissed

ITA 235/JAB/2025[2015-16]Status: DisposedITAT Jabalpur19 Feb 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 10Section 11Section 11(2)Section 143(1)Section 143(3)Section 147Section 148

undisturbed. It is not open to the assessee, in proceedings u/s 147 of I.T. Act; to raise issues unconnected with under assessment i.e. income escaping assessment. In proceedings, u/s 147 of I.T. Act, it is not open to the assessee, to claim re-computation of income or redoing of assessment

Society for Advancement in Education, Mussoorie vs. ITO Exemption Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 220/DDN/2025[2011-12]Status: DisposedITAT Dehradun18 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

merely recording “Yes. I am satisfied” and held that manners :- “ Section 151, read with section 148 of the Income-tax Act,1961 – Income escaping assessment – Sanction for issue of notice (Recording of satisfaction) – High Court by impugned order held that where Joint Commissioner recorded satisfaction in mechanical manner and without

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 219/DDN/2025[2010-11]Status: DisposedITAT Dehradun18 Feb 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

merely recording “Yes. I am satisfied” and held that manners :- “ Section 151, read with section 148 of the Income-tax Act,1961 – Income escaping assessment – Sanction for issue of notice (Recording of satisfaction) – High Court by impugned order held that where Joint Commissioner recorded satisfaction in mechanical manner and without

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 218/DDN/2025[2009-10]Status: DisposedITAT Dehradun18 Feb 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

merely recording “Yes. I am satisfied” and held that manners :- “ Section 151, read with section 148 of the Income-tax Act,1961 – Income escaping assessment – Sanction for issue of notice (Recording of satisfaction) – High Court by impugned order held that where Joint Commissioner recorded satisfaction in mechanical manner and without

Kota Radha, Vijayawada vs. Income Tax Officer, Ward-3(1), Vijayawada

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

ITA 563/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2015-16

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

Section 133(6)Section 147Section 148Section 249Section 271(1)(c)Section 69A

outside the faceless mechanism as provided under the provisions of section 144(b) r.w.s. 151A and the “E-Assessment Scheme of Income Escaping Assessment Scheme, 2022” notified by the Government of India on 29.03.2022 under section 151A were held as bad and illegal, had on the same terms allowed ... under the provisions of section 144(b) r.w.s. 151A and Page. No 6 I.T.A.No.562 & 563/VIZ/2025 Kota Radha the “E-Assessment Scheme of Income Escaping Assessment Scheme, 2022” notified by the Government of India on 29.03.2022 under section 151A were held as bad and illegal, had on the same terms

Kota Radha, Vijayawada vs. Income Tax Officer, Ward-3(1), Vijayawada

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

ITA 562/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2015-16

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

Section 133(6)Section 147Section 148Section 249Section 271(1)(c)Section 69A

outside the faceless mechanism as provided under the provisions of section 144(b) r.w.s. 151A and the “E-Assessment Scheme of Income Escaping Assessment Scheme, 2022” notified by the Government of India on 29.03.2022 under section 151A were held as bad and illegal, had on the same terms allowed ... under the provisions of section 144(b) r.w.s. 151A and Page. No 6 I.T.A.No.562 & 563/VIZ/2025 Kota Radha the “E-Assessment Scheme of Income Escaping Assessment Scheme, 2022” notified by the Government of India on 29.03.2022 under section 151A were held as bad and illegal, had on the same terms

Rajkumar Pavankumar Sharma, Makarpura vs. Income Tax Officer, Ward-4(1)(7), Vadodara

In the result, the appeal of the assessee is allowed

ITA 1821/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Rajeev Kumar Goyal, ARFor Respondent: Ms. Ketaki Desai, Sr. DR
Section 10Section 143(3)Section 147Section 17(2)(v)

issued in accordance with the faceless assessment scheme. The CIT(Appeals) examined the provisions of section 151A and the e-Assessment of Income Escaping Assessment Scheme, Rajkumar Pavankumar Sharma vs. ITO Asst. Year –2018-19 - 4– 2022 and held that the case was selected through an automated process based

Prasad Ramchandra Patil, Uran, Panvel vs. ITO Ward 3, Panvel

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

ITA 2340/PUN/2024[2017-18]Status: DisposedITAT Pune18 Feb 2026AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prakash PanditFor Respondent: Shri Amit Bobde
Section 132ASection 144Section 153ASection 69A

likely to amount to fifty lakh rupees or more in one year or in aggregate in the relevant assessment years; (ii) such income escaping assessment is represented in the form of asset which shall include immovable property being land or building or both, shares and securities, deposits in bank account ... loans and advances; (iii) the income escaping assessment or part thereof relates to such year or years; and (iv) search under section 132 is initiated or requisition under section 132A is made on or after the 1st day of April, 2017.” The Ld. AR therefore requested that the matter

Prasad Ramchandra Patil, Uran, Panvel vs. ITO - Ward 3, Panvel

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

ITA 2339/PUN/2024[2015-16]Status: DisposedITAT Pune18 Feb 2026AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prakash PanditFor Respondent: Shri Amit Bobde
Section 132ASection 144Section 153ASection 69A

likely to amount to fifty lakh rupees or more in one year or in aggregate in the relevant assessment years; (ii) such income escaping assessment is represented in the form of asset which shall include immovable property being land or building or both, shares and securities, deposits in bank account ... loans and advances; (iii) the income escaping assessment or part thereof relates to such year or years; and (iv) search under section 132 is initiated or requisition under section 132A is made on or after the 1st day of April, 2017.” The Ld. AR therefore requested that the matter

Prasad Ramchandra Patil, Uran, Panvel vs. ITO Ward 3, Panvel

Accordingly, the grounds raised by the assessee are allowed for statistical purposes

ITA 2338/PUN/2024[2014-15]Status: DisposedITAT Pune18 Feb 2026AY 2014-15

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Prakash PanditFor Respondent: Shri Amit Bobde
Section 132ASection 144Section 153ASection 69A

likely to amount to fifty lakh rupees or more in one year or in aggregate in the relevant assessment years; (ii) such income escaping assessment is represented in the form of asset which shall include immovable property being land or building or both, shares and securities, deposits in bank account ... loans and advances; (iii) the income escaping assessment or part thereof relates to such year or years; and (iv) search under section 132 is initiated or requisition under section 132A is made on or after the 1st day of April, 2017.” The Ld. AR therefore requested that the matter

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2542/KOL/2025[2015-16]Status: DisposedITAT Kolkata18 Feb 2026AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 131Section 143(2)Section 147Section 148Section 250

case of Jaganmohan Rao (supra) [sic-- Jet Airways (I) Ltd. (supra)]. We may also note that the heading of s. 147 is "Income escaping assessment" and that of s. 148 "Issue of notice where income escaped assessment". Sec. 148 is supplementary and complimentary to s. 147. Subs

Deputy Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. M/S Amluckie Investment Company Limited, Kolkata

In the result, both the appeals of the revenue are dismissed

ITA 2541/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Feb 2026AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2541 & 2542/Kol/2025 Assessment Years: 2013-14 & 2015-16 Dcit, Cc-1(2), Kolkata…………..…....…………….……….……….……Appellant Vs. M/S Amluckie Investment Company Ltd.……………….....……...…..…..Respondent 2Nd Floor, 10 Princep Street, Kolkata-700072. [Pan: Aacca6749H] Appearances By: Shri Manoj Kr. Pati, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 12, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Filed By The Revenue Are Directed Against Separate Orders Both Dated 21.07.2025 Of The Cit(A)-20, Kolkata Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Years 2013–14 2015-16 Respectively. Since Both The Appeals Relate To The Same Assessee & Arisen From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Both The Appeal Filed By The Revenue With A Delay Of 35 Days & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 131Section 143(2)Section 147Section 148Section 250

case of Jaganmohan Rao (supra) [sic-- Jet Airways (I) Ltd. (supra)]. We may also note that the heading of s. 147 is "Income escaping assessment" and that of s. 148 "Issue of notice where income escaped assessment". Sec. 148 is supplementary and complimentary to s. 147. Subs

Harleen Kaur Ghura, Mumbai vs. ITO Ward 28(1)(1), Mumbai

In the result appeal filed by the assessee is allowed

ITA 7664/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarharleen Kaur Ghura Vs. Ito, Ward 28(1)(1), B 602 Ambe Prerna, Sector Mumbai 3, Ghansoli, It-Office, Vasi Railway Navi Mumbai- 400701, Station Building, Navi Mumbai - 400703 Pan/Gir No. Aovpg9346L (Applicant) (Respondent)

Section 148Section 148ASection 151Section 151ASection 250Section 69

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. 3. On the facts

Kavita Jain, Surat vs. ITO, Ward 1(3)(2), Surat

In the result, the appeal of the assessee is allowed

ITA 428/SRT/2025[2014-15]Status: DisposedITAT Surat17 Feb 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 132Section 144BSection 147Section 148Section 149(1)Section 250Section 274Section 69

asset amounts to Rs. 50 lakhs or more. Further, para 7.1 of the said Instruction categorically provides that in cases where the income escaping assessment is less than Rs. 50 lakhs for A.Y. 2013-14, 2014-15 and 2015-16, notice under section 148 cannot be issued. For the sake ... also been noticed that notices cannot issued in a case for AY 2013-14, AY 2014-15 and AY 2015-16, if the income escaping assessment, in that case for that year, amounts to or is likely to amount to less than fifty lakh rupees. Hence, in order to reduce

Goutam Kumar Sarkar, Matigara vs. ITO, Ward 1(3), Siliguri

In the result, the appeal of the assessee is allowed

ITA 1297/KOL/2025[2013-2014]Status: DisposedITAT Kolkata17 Feb 2026AY 2013-2014

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

Section 143(2)Section 144BSection 151ASection 250

from 18.02.2021 when they were not empowered under section any Notification under section 151A about the applicability of the faceless scheme for making income escaping assessment in faceless manner prior to 29.03.2022.” 3. After hearing the rival contentions and perusing the material on record, we find that the assessee ... contentions and perusing the materials available on record, we find that the Section 151A of the Act deals with the faceless assessment or income escaping assessment and was brought on the statue book by taxation and other law (relaxation and amendment of certain provisions) Act, 2020, with effect from

Goutam Kumar Sarkar, Siliguri vs. ITO, Ward 1(3), Siliguri

In the result, the appeal of the assessee is allowed

ITA 1103/KOL/2025[2013-2014]Status: DisposedITAT Kolkata17 Feb 2026AY 2013-2014

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

Section 143(2)Section 144BSection 151ASection 250

from 18.02.2021 when they were not empowered under section any Notification under section 151A about the applicability of the faceless scheme for making income escaping assessment in faceless manner prior to 29.03.2022.” 3. After hearing the rival contentions and perusing the material on record, we find that the assessee ... contentions and perusing the materials available on record, we find that the Section 151A of the Act deals with the faceless assessment or income escaping assessment and was brought on the statue book by taxation and other law (relaxation and amendment of certain provisions) Act, 2020, with effect from

ACIT22(1), Mumbai vs. Spr Associates, Mumbai

In the result, the appeal filed by the revenue stands dismissed and the cross-objection filed by assessee stands allowed

ITA 6562/MUM/2025[2018]Status: DisposedITAT Mumbai17 Feb 2026

Bench: Smt. Beena Pillai () & Shri Arun Khodpia, ()

Section 147Section 148Section 148ASection 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

Quetzal Buildtech Private Limited, Haryana vs. Income Tax Officer, Haryana

ITA 6409/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Feb 2026AY 2016-17

Bench: Shri C.N. Prasad

Section 115BSection 139(1)Section 143(2)Section 147Section 234BSection 68Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘SMC”: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER ITA No.6409/Del/2025 Assessment

Mandeep Kaur, Fatehabad vs. ITO, Ward - 1, Fatehabad

The appeal stand allowed

ITA 630/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh16 Feb 2026AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.630/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2016-17) Ms. Mandeep Kaur Ito Ward -1 बनाम/ Vs. Vpo Museh Ali Hizrawan, Khurd, To Fatehabad Rohtak - 124001 Fatehabad, Haryana – 125050 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Datpk-9813-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Mukesh Kumar Jain (Ca) – Ld. Ar (Virtual) ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.02.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016- 17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 17-02-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144Of The Act On30-04-2023. 2. The Ld. Ar, At The Outset, Urged Legal Ground No.4 To Assail The Jurisdiction Of Ld. Ao. In This Ground Of Appeal, It Has Been Pleaded That The Order Passed U/S 148A(D) As Well As Issue Of Notice U/S 148

For Appellant: Sh. Mukesh Kumar Jain (CA) – Ld. AR (Virtual)For Respondent: Sh. Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 147Section 148Section 148ASection 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 issued under Section 148 within four years after obtaining the approval 6 Assessment ... 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