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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. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 288/RJT/2022[2013-14]Status: DisposedITAT Rajkot30 Jan 2026AY 2013-14

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

Court in ITO vs Lakhmani Mewal Das [1976 ]103 ITR 437 has lucidly explained the power of assessing officer to bring to tax income escaping assessment u/s.147 of the Act. The Hon’ble Court first held that the section provides that there must exist “reasons to believe“ and not “reasons ... believing that income of the assessee has escaped assessment. The underlying reason for that is that instances of concealed income or other income escaping assessment in a large number of cases come to the notice of the income-tax authorities after the assessment has been completed.” 46. The purpose behind

The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 275/RJT/2022[2019-20]Status: DisposedITAT Rajkot30 Jan 2026AY 2019-20

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

Court in ITO vs Lakhmani Mewal Das [1976 ]103 ITR 437 has lucidly explained the power of assessing officer to bring to tax income escaping assessment u/s.147 of the Act. The Hon’ble Court first held that the section provides that there must exist “reasons to believe“ and not “reasons ... believing that income of the assessee has escaped assessment. The underlying reason for that is that instances of concealed income or other income escaping assessment in a large number of cases come to the notice of the income-tax authorities after the assessment has been completed.” 46. The purpose behind

The Deputy Commissioner of Income Tax, Central Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 274/RJT/2022[2018-19]Status: DisposedITAT Rajkot30 Jan 2026AY 2018-19

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

Court in ITO vs Lakhmani Mewal Das [1976 ]103 ITR 437 has lucidly explained the power of assessing officer to bring to tax income escaping assessment u/s.147 of the Act. The Hon’ble Court first held that the section provides that there must exist “reasons to believe“ and not “reasons ... believing that income of the assessee has escaped assessment. The underlying reason for that is that instances of concealed income or other income escaping assessment in a large number of cases come to the notice of the income-tax authorities after the assessment has been completed.” 46. The purpose behind

The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 273/RJT/2022[2015-16]Status: DisposedITAT Rajkot30 Jan 2026AY 2015-16

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

Court in ITO vs Lakhmani Mewal Das [1976 ]103 ITR 437 has lucidly explained the power of assessing officer to bring to tax income escaping assessment u/s.147 of the Act. The Hon’ble Court first held that the section provides that there must exist “reasons to believe“ and not “reasons ... believing that income of the assessee has escaped assessment. The underlying reason for that is that instances of concealed income or other income escaping assessment in a large number of cases come to the notice of the income-tax authorities after the assessment has been completed.” 46. The purpose behind

M/S. Classic Network Limited, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Circle-1, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 3/RJT/2021[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

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

Court in ITO vs Lakhmani Mewal Das [1976 ]103 ITR 437 has lucidly explained the power of assessing officer to bring to tax income escaping assessment u/s.147 of the Act. The Hon’ble Court first held that the section provides that there must exist “reasons to believe“ and not “reasons ... believing that income of the assessee has escaped assessment. The underlying reason for that is that instances of concealed income or other income escaping assessment in a large number of cases come to the notice of the income-tax authorities after the assessment has been completed.” 46. The purpose behind

The Assistant Commissioner of Income Tax, Circle-1, Rajkot-Gujarat vs. M/S. Classic Network Limited, Rajkot-Gujarat

In the result, appeal filed by the assessee in ITA No

ITA 13/RJT/2021[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

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

Court in ITO vs Lakhmani Mewal Das [1976 ]103 ITR 437 has lucidly explained the power of assessing officer to bring to tax income escaping assessment u/s.147 of the Act. The Hon’ble Court first held that the section provides that there must exist “reasons to believe“ and not “reasons ... believing that income of the assessee has escaped assessment. The underlying reason for that is that instances of concealed income or other income escaping assessment in a large number of cases come to the notice of the income-tax authorities after the assessment has been completed.” 46. The purpose behind

Arpita Venkatesh Choulwar, Kothrud Pune vs. ITO WD-3, Pune

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

ITA 2306/PUN/2025[2016-17]Status: DisposedITAT Pune30 Jan 2026AY 2016-17

Bench: SHRI DR. DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Suhas BoraFor Respondent: Smt. Neha Thakur (Virtual)
Section 139Section 142(1)Section 144Section 147Section 148Section 148ASection 69

virtue of the Finance Act, 2021 with regards to National Faceless Assessment Proceeding, Faceless jurisdiction of Income Tax Authorities Scheme, 2022 and Income Escaping Assessment Scheme 2022. 4. The Ld. CIT(A) as well as the Ld.AO has erred in not giving an adequate opportunity to the appellant for explaining

Chandini Duvvuri, Hyderabad vs. ITO, (Int Taxn)-1, Hyderabad

In the result, both the appeals filed by the assessee are allowed in terms of our aforesaid observations

ITA 1855/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jan 2026AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1842/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) आ.अपी.सं /Ita No.1855/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siva Charan, Ca राज" व "ारा/Revenue By: Shri Sankar Pandi P, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 28/01/2026 घोषणा की तारीख/Date Of 30/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Respective Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad, Dated 04/09/2025 & 08/09/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer Under Section 147 R.W.S 144 Of The Income Tax Act, 1961 (For Short, “The Chandini Duvvuri Vs. Ito (Int. Taxn) Act”), Dated 15/05/2024 & 27/05/2025 For Ay 2016-17 & Ay 2017- 18, Respectively. As A Common Issue Is Involved In The Captioned Appeals, Therefore, The Same Are Being Taken Up & Disposed Of By Way Of A Consolidated Order. We Shall First Take Up The Appeal Filed By The Assessee For Ay 2016-17 In Ita No.1842/Hyd/2025 & The Order Therein Passed Shall Apply Mutatis Mutandis For The Purpose Of Disposing Of The Other Appeal. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri Siva Charan, CAFor Respondent: Shri Sankar Pandi P, Sr. AR
Section 147Section 148Section 148ASection 151ASection 251(1)(a)Section 69

under the provisions of Section 144(b) read with Section 151A and the "E- Chandini Duvvuri vs. ITO (Int. Taxn) Assessment Scheme of Income Escaping Assessment Scheme, 2022" notified by the Government of India on 29.03.2022 under Section 151A of the Act, is bad and illegal. Summing up his contention ... submitted that after the introduction of the "Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing

Chandini Duvvuri, Hyderabad vs. ITO, (Int Taxn)-1, Hyderabad

In the result, both the appeals filed by the assessee are allowed in terms of our aforesaid observations

ITA 1842/HYD/2025[2016-17]Status: DisposedITAT Hyderabad30 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1842/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) आ.अपी.सं /Ita No.1855/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Chandini Duvvuri, Vs. Ito (Int. Taxation)-1, Hyderabad. Hyderabad. Pan: Aympd9716A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Siva Charan, Ca राज" व "ारा/Revenue By: Shri Sankar Pandi P, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 28/01/2026 घोषणा की तारीख/Date Of 30/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Captioned Appeals Filed By The Assessee Are Directed Against The Respective Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad, Dated 04/09/2025 & 08/09/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer Under Section 147 R.W.S 144 Of The Income Tax Act, 1961 (For Short, “The Chandini Duvvuri Vs. Ito (Int. Taxn) Act”), Dated 15/05/2024 & 27/05/2025 For Ay 2016-17 & Ay 2017- 18, Respectively. As A Common Issue Is Involved In The Captioned Appeals, Therefore, The Same Are Being Taken Up & Disposed Of By Way Of A Consolidated Order. We Shall First Take Up The Appeal Filed By The Assessee For Ay 2016-17 In Ita No.1842/Hyd/2025 & The Order Therein Passed Shall Apply Mutatis Mutandis For The Purpose Of Disposing Of The Other Appeal. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri Siva Charan, CAFor Respondent: Shri Sankar Pandi P, Sr. AR
Section 147Section 148Section 148ASection 151ASection 251(1)(a)Section 69

under the provisions of Section 144(b) read with Section 151A and the "E- Chandini Duvvuri vs. ITO (Int. Taxn) Assessment Scheme of Income Escaping Assessment Scheme, 2022" notified by the Government of India on 29.03.2022 under Section 151A of the Act, is bad and illegal. Summing up his contention ... submitted that after the introduction of the "Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing

Income Tax Officer, Ward-8(1), Hyderabad vs. Dagumati Swathi, Hyderabad

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

ITA 1638/HYD/2025[2013-14]Status: DisposedITAT Hyderabad30 Jan 2026AY 2013-14

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

Section 13Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 151A

under the 4 ITO VS DAGUMATI SWATHI provisions of section 144(b) r.w.s 151A of the Act and the “E- Assessment Scheme of Income Escaping Assessment Scheme, 2022” notified by the Government of India on 29/03/2022 under section 151A, are bad and illegal; and (ii) that the notice under section ... outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 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, are bad and illegal. Summing up his contention

Ankit Jain, Hyderabad vs. DCIT., Central Circle -1(2), Hyderabad

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

ITA 1545/HYD/2025[2020-21]Status: DisposedITAT Hyderabad30 Jan 2026AY 2020-21

Bench: Us:

Section 115BSection 143(3)Section 147Section 148Section 148ASection 292CSection 69

outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 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 of the Act, is bad and illegal. Summing up his contention ... submitted that after the introduction of the "Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing

Ankit Jain, Hyderabad vs. ACIT., Central Circle - 1(2), Hyderabad

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

ITA 1544/HYD/2025[2019-20]Status: DisposedITAT Hyderabad30 Jan 2026AY 2019-20

Bench: Us:

Section 115BSection 143(3)Section 147Section 148Section 148ASection 292CSection 69

outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 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 of the Act, is bad and illegal. Summing up his contention ... submitted that after the introduction of the "Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing

Rashid Hussain, Hyderabad vs. ACIT., Central Circle-1(3), Hyderabad

ITA 1322/HYD/2025[2021-22]Status: DisposedITAT Hyderabad30 Jan 2026AY 2021-22

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

Section 143(2)Section 147Section 148Section 148ASection 151ASection 250Section 37(1)

outside the faceless mechanism as provided under the provisions of Section 144(b) read with Section 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 of the Act, is bad and illegal. Summing up his contention ... submitted that after the introduction of the "Faceless Jurisdiction of the Income Tax Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing

Ramesh Babu Bejjala, Kothagudem vs. Income Tax Officer, Ward-1, Kothagudem

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

ITA 1010/HYD/2025[2015-16]Status: DisposedITAT Hyderabad30 Jan 2026AY 2015-16

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

Section 147Section 148Section 148ASection 149(1)(b)Section 348Section 44ASection 63A

failed to appreciate that the entire reassessment proceeding initiated by the Assessing Officer was in violation of the 'e-Assessment of income Escaping Assessment Scheme, 2022', and hence both the notice and the reassessment order are vitiated in lew. 3. The learned CIT(A) erred in confirming the addition

Nevin H. Bharwani, Mumbai vs. ITO (Int Tax) Ward-1(2)(1), Mumbai

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

ITA 6318/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Jan 2026AY 2020-21

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailnevin H. Bharwani, 5Th Floor, Noor-E-Rehmat, 50 B.J. Road, Bandra West, Mumbai ............... Appellant Pan : Alrpb8270H V/S Income Tax Officer (International Taxation), Ward – 1(2)(1), Room No.530D, 5Th Floor, ……………… Respondent Kautilya Bhavan, C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra East, Mumbai - 400051 Assessee By : Shri Asif Karmali Revenue By : Shri Krishna Kumar, Sr.Dr

For Appellant: Shri Asif KarmaliFor Respondent: Shri Krishna Kumar, Sr.DR
Section 144C(13)Section 144C(5)Section 147Section 148Section 148ASection 151ASection 69Section 69A

dated 21st March 2024 in violation of the provisions of section 151A of the Act read with e-Assessment of Income Escaping Assessment Scheme, 2022. 1.2 It is submitted that in the facts and in the circumstances of the case, and in law, the order passed by the J.A.O under

Sudhir Motiram Patil, Mumbai vs. ITO, Ward 3(2), Kalyan

In the result, the appeal by the assessee is allowed

ITA 6190/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalsudhir Motiram Patil C/O Hukumchand Jain, 16Th Floor, D Wing, Trade World Kamala Mills Compound, Senapati Bapat Marg, Lower Parel, Mumbai, Maharashtra - 400013 ............... Appellant Pan: Avvpp1813G V/S Income Tax Officer, Ward-3(2), Rani Mansion, Murbad Road, ……………… Respondent Kalyan, Maharashtra – 421301 Assessee By : Shri Himanshu Gandhi, Ca Revenue By : Shri Pravin Salunkhe, Sr.Dr

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 115BSection 144BSection 147Section 148Section 148ASection 149(1)Section 149(1)(b)Section 151Section 151ASection 234A

regime before passing an order under Section 148A(d) or for issuing a notice under Section 148. (b) Under the new regime, if income escaping assessment is more than Rupees 50 lakhs, a reassessment notice could be issued after the expiry of three years from the end of the relevant

Vankar Dayabhai, Vadodara vs. The ITO, Ward-3(1)(4), Vadodara

ITA 2261/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kamble

For Appellant: Shri Akshay M. Modi, A.RFor Respondent: Shri Umesh Kumar Agrawal, Sr. D.R
Section 144BSection 147Section 148Section 151ASection 270ASection 271ASection 272A(1)(d)Section 69

vide notice dtd. 05-04-2022 after introduction of e- I.T.A Nos. 2254 to 2261/Ahd/2025 VankarDayabhai, A.Y. 2018-19 & 2019-20 Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation ... under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also

Vankar Dayabhai, Vadodara vs. The ITO, Ward-3(1)(4), Vadodara

ITA 2260/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kamble

For Appellant: Shri Akshay M. Modi, A.RFor Respondent: Shri Umesh Kumar Agrawal, Sr. D.R
Section 144BSection 147Section 148Section 151ASection 270ASection 271ASection 272A(1)(d)Section 69

vide notice dtd. 05-04-2022 after introduction of e- I.T.A Nos. 2254 to 2261/Ahd/2025 VankarDayabhai, A.Y. 2018-19 & 2019-20 Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation ... under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also

Vankar Dayabhai, Vadodara vs. The ITO, Ward-3(1)(4), Vadodara

ITA 2259/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kamble

For Appellant: Shri Akshay M. Modi, A.RFor Respondent: Shri Umesh Kumar Agrawal, Sr. D.R
Section 144BSection 147Section 148Section 151ASection 270ASection 271ASection 272A(1)(d)Section 69

vide notice dtd. 05-04-2022 after introduction of e- I.T.A Nos. 2254 to 2261/Ahd/2025 VankarDayabhai, A.Y. 2018-19 & 2019-20 Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation ... under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also

Vankar Dayabhai, Vadodara vs. The ITO, Ward-3(1)(4), Vadodara

ITA 2258/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kamble

For Appellant: Shri Akshay M. Modi, A.RFor Respondent: Shri Umesh Kumar Agrawal, Sr. D.R
Section 144BSection 147Section 148Section 151ASection 270ASection 271ASection 272A(1)(d)Section 69

vide notice dtd. 05-04-2022 after introduction of e- I.T.A Nos. 2254 to 2261/Ahd/2025 VankarDayabhai, A.Y. 2018-19 & 2019-20 Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation ... under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also