← All Phrases

“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

Baijayanti Meher, Bhubaneswar vs. ITO, Ward-2(1), Bhubaneswar

In the result, this appeal of the assessee is allowed

ITA 14/CTK/2026[2018-19]Status: DisposedITAT Cuttack27 Feb 2026AY 2018-19

Bench: Shri George Mathan & Shri Madhusudan Sawdia

Section 148Section 148ASection 271A

IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH CUTTACK BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT

Baijayanti Meher, Bhubaneswar vs. ITO, Ward-2(1), Bhubaneswar

In the result, this appeal of the assessee is allowed

ITA 13/CTK/2026[2018-19]Status: DisposedITAT Cuttack27 Feb 2026AY 2018-19

Bench: Shri George Mathan & Shri Madhusudan Sawdia

Section 148Section 148ASection 271A

IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH CUTTACK BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT

Nandyala Naga Venkata Raju, West Godavari Dist vs. Income Tax Officer, Ward-1, Tanaku

ITA 565/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2013-14
Section 147Section 148Section 69A

filed his return of income for the subject year, initiated proceedings under section 147 of the Act. Notice under section 148 of the Act dated 23.03.2021 was issued by the A.O. However, the assessee did not file his return of income. 3. Thereafter, the A.O in the course ... vide his order passed under section 147 r.w.s, 144 r.w., 144B of the Act, dated 15.03.2023, for the reason that though the notice under section 148 of the Act was issued with DIN dated 23.03.2021, but the same was served on 17.06.2021 through e-mail. Elaborating further on his contention

Jagan Mohan Rao Valluru, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-2(1), Vijayawada

ITA 469/VIZ/2025[2009-10]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2009-10

Bench: Shri Ravish Sood, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपीलसं./I.T.A.No.468/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Sai Sri Anusha Valluru 62-8, Flat No. 201 Kesava Residency Netaji Street, Patamata Vijayawada [Pan: Ahopv5451H] Vs. Dcit – Circle-2(1) C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh आयकर अपीलसं./I.T.A.No.469/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Jagan Mohan Rao Valluru Vs. Dcit – Circle-2(1) 63-1-3, Ramalayam Street Patamatalanka Vijayawada – 520010 Andhra Pradesh [Pan: Ahopv4864A] C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement : Shri C. Subrahmanyam, Ca : Shri D. Hema Bhupal, Sr.Dr : 16.02.2026 : 27.02.2026 Per Ravish Sood, Jm: आदेश /Order

Section 143(3)Section 147Section 148Section 154Section 250(6)

income for the year under consideration, i.e, A.Y. 2009-10, initiated proceedings under section 147 of the Act. Thereafter, the AO issued a notice under section 148 of the Act, dated 29.02.2016. In response, the assessee e-filed her return of income for the A.Y. 2009-10 on 09.11.2016, declaring

Sai Sri Anusha Valluru, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-2(1), Vijayawada

ITA 468/VIZ/2025[2009-10]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2009-10

Bench: Shri Ravish Sood, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपीलसं./I.T.A.No.468/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Sai Sri Anusha Valluru 62-8, Flat No. 201 Kesava Residency Netaji Street, Patamata Vijayawada [Pan: Ahopv5451H] Vs. Dcit – Circle-2(1) C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh आयकर अपीलसं./I.T.A.No.469/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Jagan Mohan Rao Valluru Vs. Dcit – Circle-2(1) 63-1-3, Ramalayam Street Patamatalanka Vijayawada – 520010 Andhra Pradesh [Pan: Ahopv4864A] C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement : Shri C. Subrahmanyam, Ca : Shri D. Hema Bhupal, Sr.Dr : 16.02.2026 : 27.02.2026 Per Ravish Sood, Jm: आदेश /Order

Section 143(3)Section 147Section 148Section 154Section 250(6)

income for the year under consideration, i.e, A.Y. 2009-10, initiated proceedings under section 147 of the Act. Thereafter, the AO issued a notice under section 148 of the Act, dated 29.02.2016. In response, the assessee e-filed her return of income for the A.Y. 2009-10 on 09.11.2016, declaring

Guntupalli Nageswara Rao, Ibrahimpatnam vs. Income Tax Officer, Ward 1(1), Vijayawada

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 379/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 147Section 148Section 148ASection 149(1)(b)Section 250Section 271(1)(c)Section 8Section 80CSection 80DSection 80E

reply, the assessee submitted that he was in possession of evidence for some of the deductions claimed by him. Thereafter, the AO issued notice under section 148 of the Act, dated 28.07.2022, wherein he called upon the assessee to file his return of income. In response, the assessee filed

Guntupalli Nageswara Rao, Ibrahimpatnam vs. Income Tax Officer, Ward 1(1), Vijayawada

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 378/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 147Section 148Section 148ASection 149(1)(b)Section 250Section 271(1)(c)Section 8Section 80CSection 80DSection 80E

reply, the assessee submitted that he was in possession of evidence for some of the deductions claimed by him. Thereafter, the AO issued notice under section 148 of the Act, dated 28.07.2022, wherein he called upon the assessee to file his return of income. In response, the assessee filed

Sitaram Muchhala, Mardana vs. ITO Khargone, Khargone

ITA 661/IND/2025[2018-19]Status: DisposedITAT Indore27 Feb 2026AY 2018-19

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

Section 142(1)Section 147Section 148Section 246ASection 250Section 253Section 45Section 56Section 57

delayed payment of compensation. However, these amounts were not fully disclosed in the return, leading to the issuance of a notice under Section 148, followed by multiple notices under Section 142(1), none of which were responded to by the appellant 6.2 A show-cause notice was issued proposing ... completed without complying with the statutory requirements of law. 6. On the facts and circumstances of the case and in law, the notice under section 148 dated 24.03.2022 is void and illegal hence liable to quashed. 7. For that the appellant craves leave to add, amend, alter vary

Ashoka Minerals, Kanpur Dehat vs. Income Tax Officer, NFAC

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

ITA 384/LKW/2025[2018-19]Status: DisposedITAT Lucknow27 Feb 2026AY 2018-19
For Appellant: Sh. Samrat Chandra, C.AFor Respondent: Sh. R.R.N. Shukla, Add CIT DR
Section 147

pertaining to the said assessment year. Therefore, proceedings under section 147 of the Income Tax Act were initiated by way of issue of notice under section 148. The AO records the fact that several notices were issued to the assessee which were not complied with. Therefore, the ld. AO issued

Smt. Kumud Yadav, Kanpur vs. Assessing Officer, NFAC, Delhi

In the result, the appeal is partly allowed

ITA 281/LKW/2025[2016-17]Status: DisposedITAT Lucknow27 Feb 2026AY 2016-17

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2016-17 Smt. Kumud Yadav, Vs. Assessing Officer, Assessment Plot No. 192A, Awadhpuri Road, Unit, Income Tax Department, Lakhanpur, Kanpur Nagar Nfac, Delhi Pan: Abjpy4062E (Appellant) (Respondent) Assessee By: Sh. Pradeep Seth, Adv Revenue By: Sh. Amit Kumar, Addl Cit Dr Date Of Hearing: 29.01.2026 Date Of Pronouncement: 27.02.2026 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), Nfac Under Section 250 Of The Income Tax Act, 1961 On 11.0.025, Wherein The Ld. Cit(A) Has Set Aside The Orders Of The Assessing Officer Passed For The A.Y. 016-17 Under Section 147 R.W.S. 144 Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “1. That The Learned Cit(A) National Faceless Appeal Centre, Delhi Has Erred In Law & On Facts In Not Appreciating That The Assessment Order Passed U/S 147 Is Without Jurisdiction & Invalid As The Same Violates The Provisions Of "E-Assessment Of Income Escaping Assessment Scheme 2022" Notified On 29.03.22 Framed In Pursuance Of Sub Sections 1 & 2 Of Section 151A Of The Act Laying Down The Issue Of Notice U/S 148 In The Faceless Manner Through Automated Allocation Whereas In The Assessee'S Case It Has Not Been Issued In A Faceless Manner But By Jurisdictional Assessing Officer Who Was Not Assigned The Case In An Automated Manner. (Reliance On Judgement In The Case Of Hexaware Technoligies Ltd. Vs. Assistant Commissioner Of Income Tax & Others Reported In 464 Itr P. 430 (Paras 32 To 39).

For Appellant: Sh. Pradeep Seth, AdvFor Respondent: Sh. Amit Kumar, Addl CIT DR
Section 144Section 147Section 148Section 148ASection 151ASection 250

assessee before the CIT(A).” 3. The facts of the case are that the case of the assessee was reopened by issuing notice under section 148 of the Act on 31.03.2023. The ld. AO records that the assessee did not make compliance during the assessment proceedings. Since, he was satisfied

Opg Sons Properties Pvt. Ltd., Sitapur vs. Income Tax Officer, Sitapur

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

ITA 256/LKW/2025[2013-14]Status: DisposedITAT Lucknow27 Feb 2026AY 2013-14

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR
Section 115BSection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 68

remained unexplained on account of this investment and for this reason, proceedings were initiated by issue of notice under section 148. No return was filed in response to this notice therefore, a further notice under section 142(1) was issued. However, as no compliance was received, the same were sent

Pankaj Agarwal, Kanpur vs. The AO Special Range, Kanpur

In the result, the appeal of the assessee is allowed

ITA 122/LKW/2024[2017-18]Status: DisposedITAT Lucknow27 Feb 2026AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Pankaj Agarwal, 7/151, Ratan Vs. The Assessing Officer, Majestic, Opp. Sony World, Special Range, Kanpur- Swaroop Nagar, Kanpur-208002 208001 Pan: Abnpa4816E (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 23.12.2025 Date Of Pronouncement: 27.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. Cit(A), Nfac Dated 9.01.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Orders Of The Ld. Ao, Special Range, Kanpur, Passed Under Section 143(3) On 26.09.2019. 2. It Is Seen From The Record That The Appeal Is Delayed By 2 Days. However, Since The Date Of Filing Is Preceded By Saturday & Sunday, Wherein The Offices Of The Itat Were Closed, The Delay Is Condoned & The Appeal Is Admitted For Hearing. The Grounds Of Appeal Are As Under: - “1. Because The Cit(A) Has Erred On Facts & In Law In Treating The Loss Of Rs.42,17,895/- Being Loss On Account Of Trading In Derivatives As A Capital Loss As Against Business Loss Claimed By The Assessee, Which Finding Of The Ao Being Contrary To Facts, Bad In Law, The Addition Made Be Deleted.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 143(3)Section 43(5)Section 44ASection 72Section 74

done under section 143(3) and no adverse inference was taken on this point and that in the assessment year 2015-16, where notice under section 148 was issued, the notice was dropped without making any such addition. Therefore, the stand of the Ld AO in this assessment year would

We Two Engineering Private Limited, Chennai vs. Commissioner of Income Tax Appeals, Chennai

The appeal of the assessee is partly allowed

ITA 3735/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3709/Chny/2025 िनधा$रण वष$ /Assessment Year: 2019-20

For Appellant: Mr. S. Girish Kumar, AdvocateFor Respondent: Dr. M.D.Vijay Kumar, JCIT
Section 148Section 250

deposited cash into Veeranam Thirumalai :- 2 -: the bank account during the year under consideration. The AO therefore reopened the assessment by issue of notice under section 148. The assessee initially did not respond to the notices but later filed the return of income. The assessee also filed details such ... paper book). The Ld. AR further submitted that the assessee has filed the return of income in response to notice under section 148 which has been considered as invalid by the AO. The Ld. AR also submitted that the estimation of profit at 8% is very high since

Vivek Ramaswamy Puthucode, Chennai vs. ITO, International Taxation Ward-2(1), Chennai

The appeal of the assessee is allowed

ITA 3731/CHNY/2025[2015-16]Status: DisposedITAT Chennai27 Feb 2026AY 2015-16

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3731/Chny/2025 िनधा&रण वष& /Assessment Year: 2015-16

For Appellant: Mr. S.Muralidhar, C.A *+For Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 148Section 148ASection 149(1)Section 250Section 54

completion during the period prescribed under TOLA; ****** 46. The ingredients of the proviso could be broken down for analysis as follows: (i) no notice under section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021; Vivek Ramaswamy ... prescribed under section 149(1)(b) of the old regime continues to exist for the assessment year 2021-2022 and before. Resultantly, a notice under Section 148 of the new regime cannot be issued if the period of six years from the end of the relevant assessment year has expired

Stp Enterprises, Tirunelveli vs. DCIT, Circle-1, Tirunelveli

The appeal of the assessee is allowed

ITA 3729/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3729/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 147Section 148Section 148ASection 151Section 250Section 69A

passed order under section 148A(d) on 04.04.2022. The assessee did not file any return or any details in response to notice under section 148. The AO completed the assessment by treating the entire cash deposit of Rs.7.22.950/- and cash withdrawal of Rs.1,71,97,500/- as unexplained credit under ... assessee. The assessee is in appeal before the tribunal against the order of the CIT(A). 3. The Ld. AR submitted that the notice under section 148 of the Act which is dated 04.04.2022 is beyond the period of 3 years and therefore, as per the provisions of Section

Veeranam Thirumalai, Madurai vs. ITO, Ncw-1(7), Madurai

The appeal of the assessee is partly allowed

ITA 3709/CHNY/2025[2019-20]Status: DisposedITAT Chennai27 Feb 2026AY 2019-20

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3709/Chny/2025 िनधा$रण वष$ /Assessment Year: 2019-20

For Appellant: Mr. S. Girish Kumar, AdvocateFor Respondent: Dr. M.D.Vijay Kumar, JCIT
Section 148Section 250

deposited cash into Veeranam Thirumalai :- 2 -: the bank account during the year under consideration. The AO therefore reopened the assessment by issue of notice under section 148. The assessee initially did not respond to the notices but later filed the return of income. The assessee also filed details such ... paper book). The Ld. AR further submitted that the assessee has filed the return of income in response to notice under section 148 which has been considered as invalid by the AO. The Ld. AR also submitted that the estimation of profit at 8% is very high since

Sri Bannari Amman Fresh Fruit, Chennai, Tamil Nadu vs. The Income Tax Officer, Non-Corporate Ward - 15(1), Chennai, Tamil Nadu

The appeal of the assessee is allowed

ITA 3702/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Feb 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3702/Chny/2025 िनधा$रण वष$ /Assessment Year: 2017-18

For Appellant: Mr. V. Tharish, CAFor Respondent: Dr. M.D. Vijay Kumar, JCIT
Section 143(1)Section 148Section 148ASection 149Section 149(1)(b)Section 151Section 250Section 68

demonetisation period to the tune of Rs.38,43,207 and passed an order under section 148A(d) on 30.07.2022. The AO issued notice under section 148 on the same day. The AO completed the assessment by adding a sum of Rs.37,22,307/- under section 68 of the Act. Aggrieved ... appeal before the tribunal against the order of the CIT(A). 3. Before us, the Ld. AR raised legal contentions that the notice under section 148 dated 30.07.2022 is barred by limitation. The Ld. AR submitted that in assessee's case the income escaping assessment is less than Rs.50 lakhs

Arehalli Rudrappa Vishwanatha, Arehally, Temple, Belur vs. Income- Tax Officer, Ward-1 & Tps, Hassan

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

ITA 2654/BANG/2025[2016-17]Status: DisposedITAT Bangalore27 Feb 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Shri Srikrishna Kantila, CAFor Respondent: Shri Balusamy N, JCIT-DR
Section 10(1)Section 142(1)Section 148Section 148ASection 250Section 44ASection 80C

IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL

Nimish Vivek Juvekar, Mumbai vs. ITO Ward 20(2)(1), Mumbai

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

ITA 6829/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant & Ms. Kavitha Rajagopal

For Appellant: Shri Dinesh ShahFor Respondent: Shri Leyaqat Ali Afaqui, SR. AR
Section 10(38)Section 142(1)Section 144Section 147Section 148Section 148ASection 151A

condition precedent to a valid assessment. 4.1 The principal legal objection raised before us pertains to li- mitation and jurisdiction in issuing notice under section 148 for A.Y. 2015-16 after 01.04.2021. However, from the material pre- sently available on record, it is not discernible: () whether any notice under

Vikas Bansal, Ajmer vs. Circle 17(1), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 5861/MUM/2025[2012-13]Status: DisposedITAT Mumbai27 Feb 2026AY 2012-13

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethvikas Bansal Vs. Circle 17(1) Plot No. 1693, Thakur 202, Kautilya Bhawan, G Block, Colony, Ram Nagar, Ajmer, Bandra Kurla Complex Rajasthan – 305001. Mumbai - 4000051 Pan/Gir No: Ahqpb6553J (Appellant) (Respondent) Appellant By None Respondent By Shri Akhtar Hussain Ansari, (Sr. Dr) Date Of Hearing 23.02.2026 Date Of Pronouncement 27.02.2026 O R D E R Per Bijyananda Pruseth, Am:

Section 143(3)Section 147Section 148Section 250Section 69Section 69C

case. The Ld. CIT(A) has erred in confirming the same. 2. The ACIT 25(1), Mumbai has erred in issuing the notice under section 148 on 30.03.2019 as he was not vested with jurisdiction over the assessee as per the instruction of the CBDT, the same was patently illegal