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“notice under section 148”

ReassessmentSection 148Section 1487,377 judgments

ANILKUMAR RAMANBHAI AMIN,VADODARA vs. INCOME TAX OFFICER, VADODARA

The appeal of the assessee is allowed for statistical purposes

ITA 2417/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2012-13

Bench: Ms. Suchitra Kamble

For Appellant: Respondent by : Shri Girish Parihar, Sr. D.RFor Respondent: Shri Girish Parihar, Sr. D.R
Section 143(3)Section 148Section 69A

Saving Bank Account. The assessee had not filed return of income. The case of the assessee was reopened by issue of notice under Section 148 of the Act. The Assessing Officer completed the assessment under Section 143(3) r.w.s. 147 of the Act dated 11.12.2019 making

WISDOM EDUCATION TRUST(R),MYSURU vs. INCOME TAX OFFICER, WARD-1(1), MYSURU

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

ITA 2501/BANG/2025[2019-2020]Status: DisposedITAT Bangalore09 Apr 2026AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri KR Vasudevan & Shri Ankur Pai, AdvocatesFor Respondent: Shri Subramanian, JCIT (DR)
Section 147Section 148Section 250Section 69A

brief are that the assessee for the year under consideration did not file any return of income. The case was reopened by issuing notice under section 148 of the Act and assessment was completed under section 147 of the Act by making an addition of cash deposits under section

WISDOM EDUCATION TRUST (R),MYSURU vs. ACIT, CIRCLE-1(1) & TPS , MYSURU

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

ITA 2029/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 Apr 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri KR Vasudevan & Shri Ankur Pai, AdvocatesFor Respondent: Shri Subramanian, JCIT (DR)
Section 147Section 148Section 250Section 69A

brief are that the assessee for the year under consideration did not file any return of income. The case was reopened by issuing notice under section 148 of the Act and assessment was completed under section 147 of the Act by making an addition of cash deposits under section

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

ITA 1254/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

assessment for the assessment year under consideration, the assumption of jurisdiction under section 147 of the Act, is invalid. The impugned notice under section 148 of the Act, therefore, cannot be sustained.” 5.3. Jurisdictional High Court on identical set of facts by reopening the assessment to disallow u/s.14A ... order passed by the CIT (Appeals). In such circumstances, the Assessing Officer could not have assumed the jurisdiction to issue the impugned notice under Section 148 of the Act on the same ground of dis-allowance under Section 14A read with Rule 8(d) of the Rules. 8. Therefore

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

ITA 1249/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

assessment for the assessment year under consideration, the assumption of jurisdiction under section 147 of the Act, is invalid. The impugned notice under section 148 of the Act, therefore, cannot be sustained.” 5.3. Jurisdictional High Court on identical set of facts by reopening the assessment to disallow u/s.14A ... order passed by the CIT (Appeals). In such circumstances, the Assessing Officer could not have assumed the jurisdiction to issue the impugned notice under Section 148 of the Act on the same ground of dis-allowance under Section 14A read with Rule 8(d) of the Rules. 8. Therefore

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1166/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2015-16

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

assessment for the assessment year under consideration, the assumption of jurisdiction under section 147 of the Act, is invalid. The impugned notice under section 148 of the Act, therefore, cannot be sustained.” 5.3. Jurisdictional High Court on identical set of facts by reopening the assessment to disallow u/s.14A ... order passed by the CIT (Appeals). In such circumstances, the Assessing Officer could not have assumed the jurisdiction to issue the impugned notice under Section 148 of the Act on the same ground of dis-allowance under Section 14A read with Rule 8(d) of the Rules. 8. Therefore

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1165/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2014-15

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

Section 115JSection 143(3)Section 144BSection 147Section 148Section 14A

assessment for the assessment year under consideration, the assumption of jurisdiction under section 147 of the Act, is invalid. The impugned notice under section 148 of the Act, therefore, cannot be sustained.” 5.3. Jurisdictional High Court on identical set of facts by reopening the assessment to disallow u/s.14A ... order passed by the CIT (Appeals). In such circumstances, the Assessing Officer could not have assumed the jurisdiction to issue the impugned notice under Section 148 of the Act on the same ground of dis-allowance under Section 14A read with Rule 8(d) of the Rules. 8. Therefore

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

available on the Insight Portal indicated that the assessee had entered into multiple financial transactions amounting to Rs. 2,94,31,158/-. Accordingly, notice under section 148 was issued on 27.03.2023. 3. In response, the assessee filed return of income on 26.04.2023 declaring total income ... Assessing Officer and the actual assessment by the faceless unit. Section 144B does not provide an exclusive machinery for pre- issuance stages of notice under section 148, and therefore the Jurisdictional Assessing Officer retains authority to issue such notices. It was further submitted that the retrospective deletion of sub-section

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 142/RPR/2026[2014-15]Status: DisposedITAT Raipur24 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

which the assessee informed the Assessing Officer that the return originally filed should be treated as the return filed pursuant to the notice under section 148 of the Act. 13. In DIT v. Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated ... escaped liability, shall serve notice specifying particulars of such claim. In view of the above, after receipt of return in response to notice under section 148, it shall be mandatory for the Assessing Officer to serve a notice under sub-section (2) of section 143 assigning reason therein...in absence

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 141/RPR/2026[2013-14]Status: DisposedITAT Raipur24 Mar 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

which the assessee informed the Assessing Officer that the return originally filed should be treated as the return filed pursuant to the notice under section 148 of the Act. 13. In DIT v. Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated ... escaped liability, shall serve notice specifying particulars of such claim. In view of the above, after receipt of return in response to notice under section 148, it shall be mandatory for the Assessing Officer to serve a notice under sub-section (2) of section 143 assigning reason therein...in absence

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, , JAIPUR vs. GOPAL PRASAD GUPTA, JAIPUR

The appeals of the revenue are dismissed

ITA 1765/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Mar 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

person other than on whom search was conducted, Section 153C is to be resorted to without giving any finding that issuance of notice under section 148 was incorrect. Thus, the CIT (A) is not justified in quashing notice issued u/s 148 of the Act. (iii) Whether the Learned ... erred in overturning the issuance of a notice under Section 148 of the Income Tax Act, 1961, despite the precedent set by the Hon. Supreme Court of India in Deputy Commissioner of Income Tax (Central) Circle 1(2) V/s. M/s. M.R. Shah Logistics Private Limited

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, JAIPUR vs. GOPAL PRASAD GUPTA, JAIPUR

The appeals of the revenue are dismissed

ITA 1764/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Mar 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

person other than on whom search was conducted, Section 153C is to be resorted to without giving any finding that issuance of notice under section 148 was incorrect. Thus, the CIT (A) is not justified in quashing notice issued u/s 148 of the Act. (iii) Whether the Learned ... erred in overturning the issuance of a notice under Section 148 of the Income Tax Act, 1961, despite the precedent set by the Hon. Supreme Court of India in Deputy Commissioner of Income Tax (Central) Circle 1(2) V/s. M/s. M.R. Shah Logistics Private Limited

BANSIWALA IRON & STEEL ROLLING MILL, JAIPUR,JAIPUR vs. DCIT CIR.-3 JAIPUR, JAIPUR

ITA 1350/JPR/2025[2010-11]Status: DisposedITAT Jaipur23 Mar 2026AY 2010-11

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Mahendra Gargieya, AdvFor Respondent: Sh. Gaurav Awasthi, JCIT

Page 1 ITA No.1350/JPR/2025 Bansiwala Iron & Steel Rolling Mill, Jaipur IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “B” BENCH

BANARSI LAL,FIROZABAD vs. ITO 2(2)(1), FIROZABAD, FIROZABAD

In the result, the appeal of the assessee is allowed

ITA 317/AGR/2025[2014-2015]Status: DisposedITAT Agra20 Mar 2026AY 2014-2015

Bench: Us Challenging The Validity Of Assumption Of Jurisdiction U/S 147 Of The Act. These Additional Grounds Go To The Root Of The Matter & The Facts Relevant For Its Adjudication Are Placed On Record. Hence, We Admit The Additional Grounds & Take Up The Same First For Adjudication.

Section 147Section 148Section 151Section 250

vehemently relied on the following decisions of Hon’ble High Courts to drive home the point where necessary sanction to issue notice under section 148 of the Act was obtained from Principal Commissioner of Income Tax as per provisions of section 151 of the Act, the Principal Commissioner

MD. BABAR ALI,MALDA vs. I.T.O., WARD - 3(1), MALDA

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

ITA 3175/KOL/2025[2020-2021]Status: DisposedITAT Kolkata20 Mar 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 234ASection 250Section 271BSection 273BSection 44A

turnover (totalling Rs. 47,17,148/-) despite the appellant declaring a total income of Rs. 4,85,200/- in response to the notice under Section 148. 6. Estimation Overrides Penalty: That since the Assessing Officer (AO) completed the assessment on an "estimated basis" by treating the books of accounts

MD. BABAR ALI,MALDA vs. I.T.O., WARD - 3(1), MALDA

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

ITA 3174/KOL/2025[2020-2021]Status: DisposedITAT Kolkata20 Mar 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 234ASection 250Section 271BSection 273BSection 44A

turnover (totalling Rs. 47,17,148/-) despite the appellant declaring a total income of Rs. 4,85,200/- in response to the notice under Section 148. 6. Estimation Overrides Penalty: That since the Assessing Officer (AO) completed the assessment on an "estimated basis" by treating the books of accounts

MD. BABAR ALI,MALDA vs. I.T.O., WARD - 3(1), MALDA

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

ITA 3173/KOL/2025[2020-2021]Status: DisposedITAT Kolkata20 Mar 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 147Section 148Section 234ASection 250Section 271BSection 273BSection 44A

turnover (totalling Rs. 47,17,148/-) despite the appellant declaring a total income of Rs. 4,85,200/- in response to the notice under Section 148. 6. Estimation Overrides Penalty: That since the Assessing Officer (AO) completed the assessment on an "estimated basis" by treating the books of accounts

NARAYAN BARTER PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER,WARD-6(1),KOLKATA, KOLKATA

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2572/KOL/2025[2011-12]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 68

issue of notice' and 'service of notice' under the 1961 Act. Section 149 prescribes the period of limitation. It categorically prescribes that no notice under section 148 shall be issued after the prescribed limitation has lapsed. Section 148(1) provides for ITA No(s). 2572/KOL/2025 Assessment Year

MANOJ RAJARAM SHARMA,THANE vs. COMMISSIONER OF INCOME-TAX, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 8313/MUM/2025[2020-2021]Status: DisposedITAT Mumbai20 Mar 2026AY 2020-2021

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarmanoj Rajaram Ito - 42(3)(4), Sharma, Mumbai Office No. 615, 6Th Vs. Kautilya Bhawan, C- Floor, Centura Square 41-43, Avenue 3, Near It Park, Sg Barve Videsh Bhavan, G Road, Thane, Block, Bkc, Mumbai Maharashtra-400 604. – 400 051. Pan/Gir No. Bytps1944K (Applicant) (Respondent) Assessee By Shri Suryadev Yadav, Shri Karan Hariya & Shri Prashant Gupta, Ld. Ars Revenue By Shri Bhagirath Ramawat, Ld. Dr Date Of Hearing 17.03.2026 Date Of Pronouncement 20.03.2026

Section 133(6)Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 272A(1)(d)Section 4Section 44A

income amounting to Rs. 2,16,59,470/- had remained unexplained and had escaped assessment. Accordingly, proceedings under section 147 were initiated and notice under section 148 dated 29.03.2024 was issued to the assessee requiring him to file return of income. During the course of assessment proceedings, notices under section

MAHESH PRAKASH BENDE,MUMBAI vs. INCOME TAX OFFICER CIRCLE 27(2), MUMBAI

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

ITA 8028/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Mar 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarmahesh Prakash Ito Circle - 27(2), Bende 4Th Floor, Tower No. 6, 302, 3Rd Floor, Prithvi Vs. It Office, Vashi Park, Sector-30, Vashi Railway Station Navi Mumbai-400 075 Building, Navi Mubmai – 400 703 Pan/Gir No. Alnpb2531M (Applicant) (Respondent) Assessee By Shri Devendra Jain, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 25.02.2026 Date Of Pronouncement 20.03.2026

Section 142(1)Section 144Section 144BSection 147Section 148Section 151Section 249Section 249(3)Section 250

escaped assessment within the meaning of section 147 of the Act. Accordingly, after obtaining approval under section 151 of the Act, a notice under section 148 dated 22.03.2021 was issued to the assessee requiring him to file the return of income. However, no compliance was made by the assessee. Subsequently

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