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“within four years”

ReassessmentSection 147Section 147391 judgments

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

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 of the Joint Commissioner, and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner

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

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: 4 Assessment Year 2017-2018 (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief

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

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 obtaining the approval of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years ... income escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner

BAJRANGLAL BHAWARLAL SHARMA,BORIVALI EAST vs. INCOME TAX OFFICER, KAUTILYA BHAVAN

ITA 285/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh SalujaFor Respondent: Shri Aditya Rai
Section 143(3)Section 144BSection 147Section 148Section 148ASection 50CSection 50C(2)

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income

SAPNA UMESH DUTTA,MUMBAI vs. ITO WARD, 41(2)(5), MUMBAI, MUMBAI

ITA 263/MUM/2026[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: passing Order, under Section 148A(d) of the Act and issuing notice dated 31/07/2022, the Assessing Officer obtained approval/sanction from the Principal Commissioner of Income Tax, Mumbai. The reassessment proceedings culminated into passing of the Assessment Order, dated 23/05/2023, under Section 147 of the Act. The appeal preferred by the Assessee against the aforesaid Assessment Order was dismissed by the CIT(A) vide Order, dated 27/11/2025. Being aggrieved, the Assessee has preferred th

For Appellant: Shri Tanmay PhadkeFor Respondent: Shri Aditya Rai
Section 147Section 148Section 148ASection 151Section 151A

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner

M/S.WELLKNOWN POLYESTERS LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(3)(1), MUMBAI, MUMBAI

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

ITA 8704/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 147Section 148Section 148ASection 151

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner

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

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: 6 I.T.A. No. 6562/Mum/2025 C.O. No. 53/Mum/2026 (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner

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

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 Year: 2016-17 of the Joint Commissioner, and (b) no notice could be issued after the expiry of four ... years; and (ii) If income escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief

SAIKAT CHINMAY BHATTACHARYA,MUMBAI vs. DY. CIT, INTERNATIONAL TAXATION, CIRCLE 1(1), BANGALORE

In the result the appeal filed by the assessee is allowed

ITA 582/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16
Section 147Section 148Section 69

{ "clean_text": "IT(IT)A No.582/Bang/2025\nSaikat Chinmay Bhattacharya, Mumbai\nIN THE INCOME TAX APPELLATE TRIBUNAL\n\"C\"BENCH: BANGALORE

ARUN DURAISWAMY,MYSORE, KARNATAKA vs. ITO, INTL. TAXATION WARD 1(1), BANGALORE

In the result the appeal filed by the assessee is allowed

ITA 193/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Deepak Gunashekar, A.RFor Respondent: Dr. Divya K.J, CIT D.R
Section 139Section 147Section 148Section 148ASection 149Section 69Section 69C

Biswanath Jhunjhunwalla 1996 taxmann.com 1141 (SC)/[1996] 5 SCC 626 the Bengal Sales Tax Rules 1941 empowered the Commissioner to revise any assessment within four years from the date of assessment. Subsequently, the State Government issued a notification following the law to extend the time limit from four years

ADARSH DEVELOPERS,MUMBAI vs. ITO, WARD 22(3)(1), MUMBAI, MUMBAI

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

ITA 7945/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Feb 2026AY 2017-18

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

Section 147Section 148Section 148ASection 151Section 151ASection 50CSection 50C(2)

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and 8 I.T.A. No. 7945/Mum/2025 (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner

DCIT CENTRAL CIRCLE- 7(1), MUMBAI, MUMBAI vs. BHAVIK PRAFULCHANDRA VORA, GUJRAT

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

ITA 7602/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 151Section 151ASection 68

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and 7 I.T.A. No. 7602/Mum/2025 C.O. No. 20/Mum/2026 (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner

DCIT CENTRAL CIRCLE- 7(1), MUMBAI, MUMBAI vs. PRANAVKUMAR PRAFULCHANDRA VORA, GUJRAT

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

ITA 7596/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 147Section 148Section 151ASection 68

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: 7 I.T.A. No. 7596/Mum/2025 C.O. No. 22/Mum/2026 (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner

DATTATRAY VITHOBA SAWANT,KALYAN vs. INCOME TAX OFFICER, WD-42(2)(2), MUMBAI

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

ITA 6081/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 10(14)Section 133ASection 142(1)Section 148Section 148ASection 151Section 151ASection 3Section 80CSection 80G

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner

NEETA BHAMBHANI,BENGALURU vs. DCIT, (IT), CIRCLE-1(1), BENGALURU

In the result, I pass the following:-

ITA 3124/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Adv. Ema Bindu, A.RFor Respondent: Dr. Divya K.J., CIT D.R
Section 10(4)(ii)Section 143(3)Section 148Section 148ASection 151Section 69

Biswanath Jhunjhunwalla 1996 taxmann.com 1141 (SC)/[1996] 5 SCC 626 the Bengal Sales Tax Rules 1941 empowered the Commissioner to revise any assessment within four years from the date of assessment. Subsequently, the State Government issued a notification following the law to extend the time limit from four years

PRABHULAL KALJI DOSHI ,MUMBAI vs. ITO WARD 19(2)(4), MUMBAI

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

ITA 7421/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 148ASection 151Section 68

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than Rupees one lakh: (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner

JAIN ENTERPRISES, BHILAI,DURG vs. PCIT, RAIPUR-1, RAIPUR

In the result, appeal of the assessee is dismissed as above

ITA 187/RPR/2025[2018-19]Status: DisposedITAT Raipur11 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 187/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Jain Enterprises, Vs Pr. Commissioner Of Income Tax, 87-B, Light Industrial Area, Raipur-1, Central Revenue Building, Bhilai-490026, C.G. Civil Lines, Raipur, 492001, C.G. Pan: Aagfj3469G (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri S. R. Rao, Advocate राज" की ओर से / Revenue By : Shri Ram Tiwari, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख / Date Of : 11/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2018-19 Filed By The Assessee Is Directed Against The Order Dated 24.03.2025 Of The Principal Commissioner Of Income Tax, Raipur-1 (‘Pcit’) Passed Under Section 263 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri S. R. Rao, AdvocateFor Respondent: Shri Ram Tiwari, CIT-DR
Section 142(1)Section 147Section 148Section 263

order by the Ld. PCIT is not valid is concerned, it is worth mentioning that the reopening of this case has been done within four years from the end of the relevant AY. Thus, the law contained in proviso to section 147 of the Act will not apply whereby ascribing

DEVANSHI SHARMA ,MUMBAI vs. ITO WARD 34(1)(1), MUMBAI

In the result, the appeal is allowed as indicated above

ITA 7007/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardevanshi Sharma Ito, Ward 34(1)(1) 216, 2Nd Floor, Kautaliya Bhawan, Sagar Jyoti, Plot No. 18, Vs. 6Th Road, Jvpd Scheme, G-Block, Bandra Kurla Complex, Vile Parle (W), Mumbai-400 056 Bandra (E), Mumbai-400 051 Pan/Gir No. Cmvpk 6007 Q (Appellant) : (Respondent) Appellant By : Shri Shashank Mehta Respondent By : Shri Annavaram Kosuri Date Of Hearing : 05.02.2026 Date Of Pronouncement : 10.02.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against Order Dated 27.10.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2017-18. 2. In Ground No. 1, The Assessee Has Raised A Pertinent Legal Issue, Challenging The Validity Of The Order Passed U/S. 148A(D) Of The Income Tax Act, 1961 (‘The Act’ For Short) As Also The Notice Issued U/S. 148 Of The Act. Since, The Aforesaid Issue Raised By The Assessee Is A Purely Legal & Jurisdictional Issue Going To The Root Of The Matter & Affecting The Validity Of The Proceedings Initiated U/S. 147 Of The Act, We Are Inclined To Address The Issue At The Very Outset.

For Appellant: Shri Shashank MehtaFor Respondent: Shri Annavaram Kosuri
Section 10(38)Section 147Section 148Section 148ASection 151

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 of the Joint Commissioner; and (b) no notice could be issued after the expiry of four years; and (ii) If income ... escaping was more than rupees one lakh : (a) a reassessment notice could be issued within four years after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner

NAGPAL ,UTTAR PRADESH vs. ITO WARD -2 (5) , CHANDAUSI

Appeal is allowed in above terms

ITA 179/DEL/2026[2018-19]Status: DisposedITAT Delhi10 Feb 2026AY 2018-19
For Appellant: Sh. V. Rajkumar, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 151

31st\nMarch 2021. According to the Income Tax Officer, in\nview of the above, Assessment Year 2015-2016 which\nfalls under the category within four years as on 31st\nMarch 2020, the statutory approval for issuance of\nnotice under Section 148 of the Act for the Assessment\nYear

KRISHNA,DELHI vs. ITO WARD 36(1), DELHI

Appeal is allowed in above terms

ITA 166/DEL/2026[2017-18]Status: DisposedITAT Delhi10 Feb 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 166/Del/2026 : Asstt. Year: 2017-18 Mrs. Krishna, Vs Income Tax Officer, G-2/57, Sector-11, Rohini, Ward-36(1), New Delhi-110085 New Delhi-110001 (Appellant) (Respondent) Pan No. Aijpd1120H Assessee By: Sh. Manish Kumar, Ca & Sh. Gaurav Bhujel, Ar Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082534866(1) Dated 12.11.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Manish Kumar, CA &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

31st March 2021. According to the Income Tax Officer, in view of the above, Assessment Year 2015-2016 which falls under the category within four years as on 31st March 2020, the statutory approval for issuance of notice under Section 148 of the Act for the Assessment Year

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