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“Section 149(1)(b)(i)”

Section References (mined)Section 149Section 149(1)(b)(i)17 judgments

The decision most relied on for Section 149(1)(b)(i) is Union of India v. Ashish Agarwal (444 ITR 1), cited in 524 judgments on BharatTax.

Leading authorities on Section 149(1)(b)(i)

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

535 (Del); 6. Tata Teleservices v. UOI
385 ITR 497 · 2016 · High Court
163
citing judgments

Orders passed under section 201(1) are barred by limitation if the prescribed period of limitation under section 201(3) had expired before the amendment by the Finance Act, 2014 came into force. The amended section 201(3) does not apply retrospectively.

7.14 In CIT v. Gwalior Rayon Silk Mfg. Co. Ltd.
196 ITR 149 · 1992 · Supreme Court
120
citing judgments

Incentive provisions in the Income-tax Act, particularly those granting deductions for new industrial undertakings, must be construed liberally to achieve their legislative purpose. This principle guides the interpretation of conditions such as what constitutes a 'new undertaking' versus a 'splitting up or reconstruction' of an existing business for claiming deductions.

Deepak Steel and Power Ltd. v. Central Board of Direct Taxes
174 Taxmann.com 144 · 2025 · Supreme Court
70
citing judgments

Reassessment notices issued after April 1, 2021, for Assessment Year 2015-16 are time-barred. The relaxation provided by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, does not extend the period of limitation for such notices.

Ravi Badalia v. DCIT
158 Taxmann.com 373 · Reported
42
citing judgments

Additions made in respect of credits reflected in foreign bank accounts for unabated assessment years must be based on incriminating material found during the search.

M B Traders v. ACIT
132 TTJ 490 · 2010 · ITAT
27
citing judgments

Section 148 notices can be issued at any time for assessments or reassessments made in consequence of or to give effect to any final finding, direction, or order of any higher authority.

B.K Gooyee v. CIT
62 ITR 109 · 1966 · High Court
26
citing judgments

A notice issued under section 34 of the Income-tax Act, 1922, that is not signed by the Income Tax Officer is invalid and considered no notice at all, as the signature is an essential and integral part of the notice.

P. Satyanarayana Chetty v. Income Tax Officer
101 ITR 385 · 1975 · High Court
25
citing judgments

Sanction for reassessment proceedings under Section 151 of the Income Tax Act must be granted with due application of mind and cannot be a mechanical or routine exercise.

Judgments citing Section 149(1)(b)(i)

Exel Rubber Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next ... finding at the time of granting the sanction as to why the reopening beyond 3 years is in accordance with the provisions of section 149(1)(b) of the Act. The alleged material which is the basis of reopening of the assessment does not reveal the fact that the income

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad.

In the result, all the six appeals i

ITA 1873/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(tii). Accordingly grant of sanction is liable to be declared as nullity and invalid and _ resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-
Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

Exel Rubber Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, all the appeals of the assessee for the

ITA 1233/HYD/2025[2019-20]Status: DisposedITAT Hyderabad24 Sept 2025AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly ... chargeable to tax represented in the form of an asset and an entry/entries in the books of account as per the prpovisions of section 149(1)(b) of the Act. Therefore, the Assessing Officer proposed to bring the case of the assessee in sub- clause(i) and sub-clause

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1207/HYD/2025[2019-20]Status: DisposedITAT Hyderabad24 Sept 2025AY 2019-20

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CA
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 grant of sanction is liable to be declared as nullity ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Exel Rubber Private Limited, K.V.Rangareddy vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1109/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Sept 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly ... chargeable to tax represented in the form of an asset and an entry/entries in the books of account as per the prpovisions of section 149(1)(b) of the Act. Therefore, the Assessing Officer proposed to bring the case of the assessee in sub- clause(i) and sub-clause

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1108/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly ... chargeable to tax represented in the form of an asset and an entry/entries in the books of account as per the prpovisions of section 149(1)(b) of the Act. Therefore, the Assessing Officer proposed to bring the case of the assessee in sub- clause(i) and sub-clause

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1107/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Sept 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly

Exel Rubber Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1106/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Sept 2025AY 2015-16
For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1088/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Sept 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1087/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 grant of sanction is liable to be declared as nullity ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1086/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Sept 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 grant of sanction is liable to be declared as nullity ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1085/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Sept 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.1084 To 1088 & 1027/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2014-15 To 2019-20)

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1084/HYD/2025[2014-15]Status: DisposedITAT Hyderabad24 Sept 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 grant of sanction is liable to be declared as nullity ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Viswanadh Kandula, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

In the result, appeals of the assessee for the A

ITA 1085/HYD/2024[2018-19]Status: DisposedITAT Hyderabad07 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1084 To 1088 & 1027/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2014-15 To 2019-20) M/S Ace Tyres (P) Ltd Vs. Acit Hyderabad Central Circle 1(2) Pan:Aadca2210N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02/09/2025 घोषणा की तारीख/Pronouncement: 24/09/2025 आदेश/Order Per Vijay Pal Raothese Six Appeals By The Assessee Are Directed Against The Six Separate Orders Dated 29/05/2025, 30/05/2025, 04/06/2025, 096/06/2025, 17/06/2025 & 14/07/2025 Of The Learned Cit (A)-11, Hyderabad Arising From The Assessment Order Passed U/S 143(3) R.W.S. 147 Of The Act, Pursuant To The Search & Seizure Operations U/S 132 Of The Act, Dated 04/01/2023 In Case Of Exel Group Of Companies Including The Assessee For The A.Ys 2014-15 To 2019-20 Respectively. Since Common Issues Are Raised In These Group Of Six Appeals Arising From Same Facts & Search & Seizure Operation, Therefore, For The Sake Of Convenience, All Page 1 Of 78

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 ITA Nos 1084 to 1088 and 1207 of 2025 ACE Tyres ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned