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“notice under section 148”

ReassessmentSection 148Section 1487,377 judgments

The decision most relied on for notice under section 148 is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on notice under section 148

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

CIT v. Sinhgad Technical Education Society
397 ITR 344 · 2017 · Supreme Court
1,589
citing judgments

For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

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.

Union of India v. Rajeev Bansal
469 ITR 46 · 2024 · Supreme Court
713
citing judgments

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

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.

Tin Box Company v. CIT
249 ITR 216 · 2001 · Supreme Court
624
citing judgments

When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.

Judgments citing notice under section 148

The Estate Investment Company Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

ITA 3012/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Oct 2025AY 2014-15
Section 132Section 132(4)Section 69A

Apart from the aforesaid grounds on merits of the addition, the Assessee has also raised legal grounds regarding the validity of the Notice under section 148 & validity of DIN on the Assessment Order. Submissions of the A.R: 17. The matter was argued at length before us. The Assessees have also ... Assessing officer 33 ITA No.3012/Mum/2025 and others The Estate Investment Company Pvt. Ltd. and others (i) The AR also pointed out that the notice under section 148 was issued by jurisdictional Assessing officer in contravention of Section 151A of the Act & the scheme frame thereafter and therefore the reassessment proceedings

Rajiv Kumar Choudhary, Bareilly vs. Income Tax Officer, Ward - 3(2)(4), Muzaffarnagar

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

ITA 3411/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2016-17 Rajiv Kumar Chaoudhary, Vs. Ito 141, Utsav Part-2, Ward- 3 (2)(4) Mahanagar Pilbhit Road, Muzaffarnagar Bareilly 243006 Uttar Pradesh Bareilly Pan No.Aftpc3123Q (Appellant) (Respondent)

Section 147Section 148Section 148ASection 151

considering the case of the petitioner as fit case for invoking reassessment proceedings under section 147 of the Act by issuance of notice under section 148, by erroneously treating the agricultural receipts of the family which was deposited in the bank accounts of the appellant as alleged income which ... filed the return of income for the A.Y.2016-17. The case of the assessee was reopened u/s 147 of the Act and notice under section 148 dated 22-03- 2023 was issued to the assessee. In the response of the notice the assessee filed his return of income declaring total income

Ajit Pal Singh Choudhary, Delhi vs. Assistant Commissioner of Income Tax, Circle 43(1), Delhi

In the result the appeal of the assessee is allowed

ITA 3395/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Oct 2025AY 2016-17

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwal Accoutant Member Assessment Year: 2016-17 Ajit Pal Singh Choudhary Vs. Assistant Commissioner Of A-139, Meera Bagh New Income Tax Circle 43(1) Delhi 110087 Pan No. Acrpc1266D (Appellant) (Respondent)

Section 147Section 148Section 149Section 151Section 151ASection 153CSection 156Section 157ASection 69

1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “E”, DELHI BEFORE SH. SUDHIR KUMAR JUDICIAL MEMBER AND SH. MANISH

Deepak Kumar Gupta, Kanpur vs. ITO Ward 2(1), Moradabad

In the result, appeal of the Assessee is partly allowed as indicated above

ITA 4528/DEL/2024[2014-15]Status: DisposedITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2014-15 Deepak Kumar Gupta, Vs. Income Tax Officer, 7/115, Flat No. B-1, Sai Niwas, Ward 2(1), Arya Nagar, Kanpur - 208020 Moradabad ( U.P) Uttar Pradesh. Pin: 244 001 Pan :Acmpg1836E (Appellant) (Respondent)

Section 142(1)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 271FSection 69

During verification, assessee failed to provide the source of investments. After recording reasons and obtaining necessary approval of the Competent Authority, notice under Section 148 dated 31.3.2021 was issued. The assessee claimed that he has e-file return of income in response to the notice under Section 148 ... from the due date as per notice. Penalty proceedings under Section 271F of the Act for non-filing of ITR In response to notice under Section 148 of the Act on 31.03.2021 by the prescribed period initiated separately. Notice under Section 142(1) of the Act dated 04.12.2021 was issued

Deputy Commissioner of Income Tax, Jhandewalan, New Delhi vs. Israni Buildwell Private Limited, Delhi

ITA 3132/DEL/2024[2014-15]Status: HeardITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 148Section 194CSection 194ISection 68Section 69Section 69C

have reason to believe that entire transaction either paid/received total of Rs.9,98,92,814/- has escaped assessment....." 3.1 In response to the notice under section 148 of the Income Tax Act, 1961 (‘Act’), the respondent assessee filed its ITR on 24.01.2022 declaring income of Rs.13,83,860/-. The case ... Sunny Israni. The sale of said property had been duly disclosed in the books of accounts and ITR filed in response to the notice under section 148 of the Act. It was further submitted that this transaction dully got reflected in the assessee’s 26AS based on the Annual Information

Raheja Developers Limited, New Delhi vs. DCIT, Central Circle 19, New Delhi

ITA 2284/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

learned Commissioner of income Tax (Appeals) has erred in not sustaining the contention of the appellant that the assessing officer has issued notice under section 148 without application of mind. 3. That the learned Commissioner of Income Tax (Appeals) has erred in not sustaining the contention of the appellant that

Raheja Developers Limited, New Delhi vs. ACIT, Central Circle 19, Delhi

ITA 2283/DEL/2023[2011-12]Status: DisposedITAT Delhi17 Oct 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

learned Commissioner of income Tax (Appeals) has erred in not sustaining the contention of the appellant that the assessing officer has issued notice under section 148 without application of mind. 3. That the learned Commissioner of Income Tax (Appeals) has erred in not sustaining the contention of the appellant that

Balwinder Kaur, Moga vs. Income Tax Officer Ward-1, Moga

The appeal stand allowed in terms of our above order

ITA 593/ASR/2024[2019-2020]Status: DisposedITAT Amritsar16 Oct 2025AY 2019-2020

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकरअपीलसं./ Ita No. 593/Asr/2024 (िनधा"रणवष" / Assessment Year: 2019-20) Ms. Balwinder Kaur Ito- बनाम/ Patti Machhiki Machhike, Ward-1 Machhike Nihal Singh Wala, Moga-142039 Vs. Moga-142039, Punjab Punjab "ायी लेखा सं./Pan. Gzwpk-8896-M (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Shri Manoj Kumar (Ca) - Ld. Ar ""थ"कीओरसे/Respondent By : Shri Charan Dass (Addl. Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 13-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 16/10/2025 आदेश / O R D E R

For Appellant: Shri Manoj Kumar (CA) - Ld. ARFor Respondent: Shri Charan Dass (Addl. CIT) - Ld. Sr. DR
Section 144BSection 147Section 148Section 148ASection 151A

From the perusal of Section 151A, it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable ... notice under Section 148. Even otherwise, it is a settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Jurisdictional Assessing Officer

Income Tax Officer-2(1), Indore, Aayakar Bhawan Indore vs. Gurdeep Singh Chhabra, Indore

ITA 726/IND/2024[2014-15]Status: DisposedITAT Indore16 Oct 2025AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 147Section 148Section 148A

Subject: Subsequent proceedings with reference to section 148A(b) in consequence to Hon'ble SC Order dated 04.05.2022 - Letter Please refer to the notice under section 148 of the Income Tax Act, 1961 dated 22 /04/2021 for the Assessment Year as mentioned above. In compliance to the judgement ... under section 148A(d) of Income Tax Axt, 1961 should not be passed holding that it is a fit case for issue of notice under section 148 of Income Tax Axt, 1961 and notice under section 148 of Income Tax Act should not be issued for the Assessment Year

Anguri Devi Khandelwal (Radha Mohan Khandelwal (Legal Heir), Jaipur vs. DCIT Circle-4, Jaipur

ITA 389/JPR/2025[2018-19]Status: DisposedITAT Jaipur16 Oct 2025AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Rohan Sogani, Ld. C.AFor Respondent: Shri Gaurva Awasthi, Ld. JCIT
Section 139(1)Section 142(1)Section 143Section 148A

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B-Bench” JAIPUR Jh xxu xks

Aryavart Bank, Lucknow vs. Dy. Commissioner of Income Tax, Range-1, Lucknow

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

ITA 800/LKW/2024[2012-13]Status: DisposedITAT Lucknow16 Oct 2025AY 2012-13

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2012-13 Uttar Pradesh Gramin Bank, Vs. Dcit-Range 1, (Successor To Erstwhile Allahabad U.P. Lucknow Gramin Bank), Head Office, 2Nd & 3Rd Floor, Nbcc Commercial Complex, Vardan Khand, Gomti Nagar Extension, Lucknow Pan: Aaaju0568R (Appellant) (Respondent) Assessee By: Sh. C. Naresh, Fca Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 28.07.2025 Date Of Pronouncement: 16.10.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A) Setting Aside The Orders Of The Ld. Assessing Officer That Were Passed Under Section 147 R.W.S. 144 On 30.12.2019. The Grounds Of Appeal Are As Under:- “1. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A), Nfac Erred In Not Granting Opportunity To The Appellant Bank To Present The Case Through Video Conferencing As Specified Under Faceless Appeal Scheme, 2020 Provided U/S. 250(68) Of The Income Tax Act, 1961 ("The Act"). The Hon'Ble Cit(A) Be Directed To Grant Personal Hearing Through Video Conferencing In The Interest Of Justice. Without Prejudice To The Above 2. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A) Erred In Invoking The Provisions Of Proviso To Section 251(1)(A) & Setting Aside The Order To Ao Without Appreciating That The Order Was Not Passed U/S 144. 3. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A) Failed To Appreciate That The Din Was Issued In The Name Of Non-Existing Entity & Hence The Order Passed Is Invalid. Without Prejudice To The Above

For Appellant: Sh. C. Naresh, FCAFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 144Section 147Section 148Section 234ASection 244ASection 250(68)Section 251(1)(a)Section 36(1)(viia)Section 80P

turn amalgamated into Aryavart Bank, which is the present entity. As no return had been filed by Gramin Bank of Aryavart, a notice under section 148 was issued to that assessee. In response, it was submitted that the entity Gramin Bank of Aryavart had come into existence w.e.f. 1.04.2013, hence ... successor entity to these banks. The order was passed under section 144 as no return of income was filed in response to the notice under section 148. 3. Aggrieved with the said orders, the assessee went in appeal to the ld. CIT(A). The ld. CIT(A) records the fact

Bhagwant Kaur, Mohali vs. Income Tax Officer, Ward-6(1), Chandigarh

In the result, appeal of the Assessee is dismissed

ITA 122/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh16 Oct 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal. C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 142(1)Section 144Section 148Section 148rSection 251(1)(a)Section 69

information available with the department, the Assessing Officer noted that no return of income had been filed by the assessee. Consequently, a notice under section 148 was issued on 30.03.2021. 3.1 Despite the issuance of notice under section 148 and subsequent notice under section 142(1) along with a questionnaire

Seth Industrial Corporation, Ludhiana, Punjab vs. Deputy Commissioner of Income Tax, Central Circle-3, Ludhiana, Punjab

Appeal stand allowed in terms of our above order

ITA 874/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh16 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1044/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2018-19) Dcit-Central Circle-3 M/S Seth Industrial Corporation बनाम/ Aaykar Bhawan, Rishi Nagar 80-A, Industrial Estate Vs. Ludhiana – 141001 Ludhiana, Punjab - 141003 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aakfs-2622-J (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.874/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Seth Industrial Corporation Dcit-Central Circle-3 बनाम/ 80-A, Industrial Estate Aaykar Bhawan, Rishi Nagar Vs. Ludhiana, Punjab - 141003 Ludhiana – 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aakfs-2622-J (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Tej Mohan Singh (Advocate) – Ld. Ar Revenue By : Smt. Geetinder Mann (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 16-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 16/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Cross-Appeals For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana [Cit(A)] Dated 18-07-2024 In The Matter Of An Assessment

For Appellant: Shri Tej Mohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Geetinder Mann (CIT) – Ld. DR
Section 132(1)Section 144BSection 147Section 148Section 148ASection 151ASection 69

From the perusal of Section 151A, it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable ... notice under Section 148. Even otherwise, it is a settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Jurisdictional Assessing Officer

DCIT, CC-3, Ludhiana, Kitchlu Nagar vs. Seth Industrial Corporation, Millerganj

Appeal stand allowed in terms of our above order

ITA 1044/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh16 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1044/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2018-19) Dcit-Central Circle-3 M/S Seth Industrial Corporation बनाम/ Aaykar Bhawan, Rishi Nagar 80-A, Industrial Estate Vs. Ludhiana – 141001 Ludhiana, Punjab - 141003 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aakfs-2622-J (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / Ita No.874/Chandi/2024 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Seth Industrial Corporation Dcit-Central Circle-3 बनाम/ 80-A, Industrial Estate Aaykar Bhawan, Rishi Nagar Vs. Ludhiana, Punjab - 141003 Ludhiana – 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aakfs-2622-J (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Tej Mohan Singh (Advocate) – Ld. Ar Revenue By : Smt. Geetinder Mann (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 16-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 16/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Cross-Appeals For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana [Cit(A)] Dated 18-07-2024 In The Matter Of An Assessment

For Appellant: Shri Tej Mohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Geetinder Mann (CIT) – Ld. DR
Section 132(1)Section 144BSection 147Section 148Section 148ASection 151ASection 69

From the perusal of Section 151A, it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable ... notice under Section 148. Even otherwise, it is a settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Jurisdictional Assessing Officer

Indian Ion Exchange & Chemicals Limited, Ahmedabad vs. The ITO, Ward-2(1)(1) Previously Ward-2(1)(3), Ahmedabad

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

ITA 1420/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2014-15

Section 143(3)Section 147Section 148

information received that the assessee had made transactions with an accommodation entry provider in respect of purchases of Rs.92,20,100/-. Accordingly, a notice under Section 148 of the Act was issued on 22.03.2019. In the course of assessment, the Assessing Officer made addition of Rs.92,20,100/- on account

M/S. Shree Renuka Sugars Limited (Successor in Interest of M/S. Monica Trading Private Limited), Mumbai vs. Deputy Commissioner of Income Tax Circle 7(1)(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 4506/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarm/S. Shree Renuka Sugars V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle – (Successor In Interest Of M/S 7(1)(1), Aayakar Bhavan, Monica Trading Pvt. Ltd.),2Nd& M.K. Road, Mumbai – 3Rd Floor, Kanakshree Arcade, 400020, Maharashtra Jnmc Road, Nehru Nagar, Belagavi – 590 010, Karnataka स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs1728B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri K.K. Chythanya, Sr. Adv. & Tata Krishna, AdvFor Respondent: Shri Umashankar Prasad, (CIT-DR)
Section 144Section 147

assessment was completed under section 143(3) of the Act by accepting the returned loss. Subsequently, the AO issued a notice under section 148 of the Act on the predecessor directing it to file its return of income. Thereafter, he passed the reassessment order under section 147 read with section

Shambu Dayal Modi, Modi Plastic Udyog vs. Assessing Officer, ITO Ward

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

ITA 168/RAN/2025[2018-19]Status: DisposedITAT Ranchi15 Oct 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.168/Ran/2025 Assessment Year: 2018-19 Shambu Dayal Modi………….……………............................……….……Appellant Modi Plastic Udyog, Mini Shed No.-31, 32, Phase-Iii, Adityapur Industrial Area, Adityapur, Jamshedpur, Seraikela-Kharsawan, Jharkhand-832109, Jamshedpur, Jharkhand – 832109. [Pan: Akxpm9308G] Vs. Ito, Ward-3(1), Jamshedpur...…..….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 15, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 19.03.2025 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2012–13. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018–19 Declaring A Total Income Of ₹5,45,350/-. Subsequently, The Assessing Officer Received Information That The Assessee Was Allegedly Involved In Gst Evasion By Facilitating Purchases Without Actual Movement Of Goods. As Per The Information Received From The Gst Database, The Assessee Had Shown Purchases Amounting To ₹13,12,816/- From M/S. Tumbqun Plastic During The Year Under Consideration. Based On This Information, The Assessing Officer Initiated Proceedings Under Section 148A(B) Of The Income-Tax Act, 1961

Section 144Section 148Section 148ASection 250

Assessing Officer initiated proceedings under section 148A(b) of the Income-tax Act, 1961, I.T.A. No.168/Ran/2025 Shambu Dayal Modi and thereafter issued notice under section 148 of the Act. Several statutory notices were issued to the assessee, calling for explanations and supporting documents. However, the assessee failed to comply with

Renu Lata Tiwary, Ranchi vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 161/RAN/2025[2012-13]Status: DisposedITAT Ranchi15 Oct 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.161/Ran/2025 Assessment Year: 2012-13 Renu Lata Tiwary…..………….……………............................……….……Appellant Regional Director Animal Husbandry Kanke, Ranchi, Jharkhand – 834008. [Pan: Aeept2902C] Vs. Ito, Ward-2(5), Ranchi….....…..….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 15, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 26.09.2023 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”).

Section 142(1)Section 144Section 148Section 250

capital gains arising from such sale had been disclosed in the return of income. Accordingly, after obtaining the necessary approval from the CIT, notice under section 148 of the Income-tax Act, 1961 was issued to the assessee. However, the assessee did not file any return of income in response

Prabhu Dayal Bhartiya, Patna vs. Dc/Ac Circle-4, Patna

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

ITA 372/PAT/2025[2013-14]Status: DisposedITAT Patna15 Oct 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.372/Pat/2025 Assessment Year: 2013-14 Prabhu Dayal Bhartiya (Huf)….………. …………………....Appellant 701, Shanti Kunj, Chajjubagh, Patna, Bihar- 800001.. [Pan: Aachp7738Q] Vs. Dc/Ac, Circle-4, Patna…....…..……………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 15, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Is Directed By The Assessee Against The Order Dated 16.07.2025 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee, A Hindu Undivided Family (Huf), Filed Its Return Of Income For The Assessment Year 2013– 14 Declaring A Total Income Of ₹6,120/-. The Case Was Reopened Under Section 147 Of The Income-Tax Act, 1961 On The Basis Of Information Received From The Investigation Wing That The Assessee Was A Beneficiary Of Accommodation Entries In The Form Of Long-Term Capital Gains (Ltcg) From The Sale Of Shares Amounting To ₹55,16,804/- Received From M/S. Aayan Commercial Pvt. Ltd. & Its Associate Concerns. It

Section 10(38)Section 147Section 148Section 250Section 68

section 10(38) of the Act on account of such alleged bogus LTCG. Accordingly, after obtaining the necessary approval from the competent authority, notice under section 148 of the Act was issued to the assessee. During the reassessment proceedings, the assessee failed to substantiate the genuineness of the share transactions

Shardindu Prasad Singh, Patna vs. ITO, Ward-6(4), Patna

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

ITA 630/PAT/2024[2016-17]Status: DisposedITAT Patna15 Oct 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 250Section 271(1)(c)

officer has not supplied 'or' served the only reasons recorded to believe on the escapement of income to the appellant before issuing any notice under Section 148 of Income Tax Act 1961. Although, the Assessing Officer has to record reasons in writing, stating why the assessee in question, is believed ... escaped assessment. A simple assertion of 'reason to believe' in writing in assessment order is not enough to validate the issuance of a notice under Section 148. Your good-self may examine the fact stated above from the records of learned assessing officer about reasons recorded and the same