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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

ACIT, Circle-1, Bhavnagar vs. Mahadev Shipbreakers Pvt Ltd., Bhavnagar

In the result, the appeal of the Revenue is dismissed

ITA 724/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad22 Sept 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalthe Assistant Commissioner Mahadev Shipbreakers Pvt. Ltd., Vs. Of Income Tax, Office No. 213/216, 2Nd Floor, Circle-1, Samved Complex, Opp. Jail Bhavnagar Road, Bhavnagar-364001 [Pan :Aaecm 8398 J] (Appellant) .. (Respondent) Appellant By : Shri Abhijit, Sr. Dr Respondent By: Shri Tushar Hemani, Sr. Advocate & Shri Kushal Fofaria, Ar Date Of Hearing 17.09.2025 Date Of Pronouncement 22.09.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri Abhijit, Sr. DRFor Respondent: Shri Tushar Hemani, Sr. Advocate &
Section 115BSection 148Section 148ASection 250Section 270A(9)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Vilasben Purohit, Mumbai vs. Income Tax Officer 42(1)(5), Mumbai

ITA 4879/MUM/2025[2016-2017]Status: DisposedITAT Mumbai22 Sept 2025AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vilasben Purohit, Ito 42(1)(5), A 404, Snehal Tower, Sayar Pada, Kautilya Bhavan, Bandra Kurla Borivali, Vs. Complex, Mumbai-400066. Mumbai-400051. Pan No. Aqqpp 6847 J Appellant Respondent

For Appellant: Ms. Kavitha Kaushik, Sr. DRFor Respondent: Mr. Ashish Thakurdesai
Section 148Section 148ASection 234ASection 234BSection 69

passed on Accordingly, order under section 148A(d) of the Act was passed on Vilasben Purohit 13.03.2023 and notice under section 148 was issued on the same 13.03.2023 and notice under section 148 was issued on the same 13.03.2023 and notice under section 148 was issued on the same date

DCIT-19(1), Mumbai vs. Anish Piyush Kothari, Mumbai

In the result, the CO filed by the assessee is allowed and appeal filed by the revenue is dismissed

ITA 3927/MUM/2025[1997-98]Status: DisposedITAT Mumbai22 Sept 2025AY 1997-98

Bench: Shri Sandeep Gosain

Section 13Section 147Section 148Section 149Section 250

issuance of notice was ten years from the end of the relevant assessment year. Thus the period of limitation for issue of notice under Section 148 of the Act was as under: Particulars Date End of AY 1997-98 31.03.1998 Expiry of limitation period 31.03.2008 Date of Notice ... view, the extended period of limitation under the amended provisions would be applicable to those assessments where the time limit to issue notice under section 148 had not expired as on the date of the amended provisions i.e. 1st July, 2012. As the same is clarified in Explanation to Section

Jayantilal Rajmal Seth, Mumbai vs. DCIT-CC-4(3), Mumbai

ITA 3260/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Jayantilal Rajmal Seth, Dcit-Cc-4(3), A-3, Saibaba Shopping Centre, Bkc, Mumbai-400051. Mumbai Central, Vs. Mumbai-400008. Pan No. Agepj 0499 E Appellant Respondent

For Appellant: Mr. Vivek Perampurna, CIT-DRFor Respondent: Mr. Jayant Bhat
Section 139(5)Section 148Section 263

from M/s Aneri Fincap Ltd. Acting upon such accommodation entry from M/s Aneri Fincap Ltd. Acting upon such information, the Assessing Officer issued notice under section 148 information, the Assessing Officer issued notice under section 148 information, the Assessing Officer issued notice under section 148 ... income at the stage of to conclusively prove escapement of income at the stage of issuance of notice under section issuance of notice under section 148. It is not the requirement of 148. It is not the requirement of law that at the stage of the reopening the assessment

Mr. Jatin Harish Sotta, Mumbai vs. Income Tax Officer Ward 26(1)(7), Mumbai

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

ITA 1916/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 Sept 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Mr. Jatin Harish Sotta, Ito Ward 26(1)(7), A-16, Ajanta Apartment, C-41 To C-43, G Block, Bkc, Murar Road, Mulund West, Vs. Bandra (East), Mumbai-400080. Mumbai-400051. Pan No. Aqfps 6009 N Appellant Respondent

For Appellant: Ms. Kavita Kaushik, Sr. DRFor Respondent: Mr. Nimesh Chothani, CA
Section 144Section 147Section 69A

escaped assessment, and accordingly issued notice under section escaped assessment, and accordingly issued notice under section escaped assessment, and accordingly issued notice under section 148 on 31.03.2019. No return was filed in response, nor were 148 on 31.03.2019. No return was filed in response, nor were 148

Vipendra Ravindra Mandal, Thane vs. Income Tax Officer- Ward 22(3)(6), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1819/MUM/2025[2016-2017]Status: DisposedITAT Mumbai22 Sept 2025AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vipendra Ravindra Mandal, Ito Ward 22(3)(6), 405, Orchid Wing-F Lodha Crown, Piramal Chamber, Taloja Bypass Road, Kohni B.O. Vs. Mumbai-400012. Khoni, Thane-421204. Pan No. Alepm 8472 H Appellant Respondent

For Appellant: Mr. V.P. KothariFor Respondent: Mr. Bhagirath Ramawat, Sr. DR
Section 148Section 148ASection 149(1)(A)Section 54

under Section 148A(d) of the Act and authority, passed an order under Section 148A(d) of the Act and thereafter issued a notice under Section 148 of the Act requiring the thereafter issued a notice under Section 148 of the Act requiring the thereafter issued a notice under Section ... present below the monetary threshold of ₹50 lakhs as prescribed for below the monetary threshold of 50 lakhs as prescribed for issuance of notice under Section 148 of the Act beyond a period of issuance of notice under Section 148 of the Act beyond a period of issuance of notice

Basudeo Soni, New Delhi vs. ITO Ward 35(1), New Delhi

Appeal is allowed in above terms

ITA 4894/DEL/2025[2016-17]Status: DisposedITAT Delhi22 Sept 2025AY 2016-17

Bench: Sh. Satbeer Singh Godaraita No. 4894/Del/2025 : Asstt. Year : 2016-17 Basudeo Soni, Vs Income Tax Officer, C/O B-50, Lgf, South Extension-Ii, Ward-35(1), New Delhi-110049 New Delhi (Appellant) (Respondent) Pan No. Agyps4983N Assessee By: Sh. Saantanu Jain, Adv. & Ms. Jahanvi Khanna, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.09.2025 Date Of Pronouncement: 22.09.2025

For Appellant: Sh. Saantanu Jain, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 13ASection 147Section 148Section 148ASection 29A

declaring a NIL income, after claiming exemption under Section 13A of the Income Tax Act, 1961. 3. The initial notice under Section 148 of the Act for AY 2016-17 was issued on 28.06.2021. The said notice was unsustainable as it was issued in accordance with the statutory regime ... petitioner’s case that the said notice is barred by limitation. 9. It is material to note that the original notice under Section 148 of the Act [deemed to be a show cause notice under Section 148A(b) of the Act in terms of the decision in the case

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2006/DEL/2025[2016-17]Status: DisposedITAT Delhi22 Sept 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

learned CIT(A) has erred both on facts and in law in confirming the reopening of the reassessment proceedings despite the fact that notice under section 148 has been issued beyond three years without there being any books of accounts, evidence or other documents in the possession ... fact that the order under Section 147 r.w.s. 144 has been passed ignoring the first proviso to section 148 which provides that notice under section 148 shall not be issued unless there is "information" [as defined under Explanation 1 to section 148] with the assessing officer which suggests that income

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2005/DEL/2025[2015-16]Status: DisposedITAT Delhi22 Sept 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

learned CIT(A) has erred both on facts and in law in confirming the reopening of the reassessment proceedings despite the fact that notice under section 148 has been issued beyond three years without there being any books of accounts, evidence or other documents in the possession ... fact that the order under Section 147 r.w.s. 144 has been passed ignoring the first proviso to section 148 which provides that notice under section 148 shall not be issued unless there is "information" [as defined under Explanation 1 to section 148] with the assessing officer which suggests that income

Gomesh Dwivedi, Padra Rewa vs. ITO-Rewa, Ditrict Rewa (Mp), Rewa

In the result, ITA Nos. 15 & 16/JAB/2024 are held to be allowed for statistical purposes

ITA 16/JAB/2024[2013-14]Status: DisposedITAT Jabalpur19 Sept 2025AY 2013-14

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.15 & 16/Jab/2024 A.Ys. 2012-13 & 2013-14 Gomesh Dwivedi, Vs. Income Tax Officer, Ward No.3, Durga Nagar Padra Huzur Rewa, M.P. Rewa, M.P. Pan:Akcpd5536A (Appellant) (Respondent)

For Appellant: Sh. Abhijeet Shrivastava, AdvocateFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 144Section 147Section 148Section 250

Gomesh Dwivedi F.Y. 2011-12 but not shown this transaction in his ITR. Accordingly, proceedings under section 147 were initiated by issue of notice under section 148 on the grounds that the assessee had invested Rs.23,42,857/- in the part purchase of agricultural lands situated at Chourahata, Rewa alongwith ... Dileep Kumar Rajwani and five other persons. In response to the notice under section 148, the assessee filed a letter in which it was submitted, that he had already filed his ITR on 27.11.2012 and therefore, the proceedings should be stopped. He did not furnish any other details. Later, show

Gomesh Dwivedi, Padra vs. ITO-Rewa, District Rewa (Mp), Rewa

In the result, ITA Nos. 15 & 16/JAB/2024 are held to be allowed for statistical purposes

ITA 15/JAB/2024[2012-13]Status: DisposedITAT Jabalpur19 Sept 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.15 & 16/Jab/2024 A.Ys. 2012-13 & 2013-14 Gomesh Dwivedi, Vs. Income Tax Officer, Ward No.3, Durga Nagar Padra Huzur Rewa, M.P. Rewa, M.P. Pan:Akcpd5536A (Appellant) (Respondent)

For Appellant: Sh. Abhijeet Shrivastava, AdvocateFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 144Section 147Section 148Section 250

Gomesh Dwivedi F.Y. 2011-12 but not shown this transaction in his ITR. Accordingly, proceedings under section 147 were initiated by issue of notice under section 148 on the grounds that the assessee had invested Rs.23,42,857/- in the part purchase of agricultural lands situated at Chourahata, Rewa alongwith ... Dileep Kumar Rajwani and five other persons. In response to the notice under section 148, the assessee filed a letter in which it was submitted, that he had already filed his ITR on 27.11.2012 and therefore, the proceedings should be stopped. He did not furnish any other details. Later, show

Rajesh Singh, Rewa vs. ITO Ward-1 Rewa, Rewa

In the result, appeal in ITA No

ITA 129/JAB/2023[2010-11]Status: DisposedITAT Jabalpur19 Sept 2025AY 2010-11

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.128 & 129/Jab/2023 A.Y. 2010-11 Rajesh Singh, Vs. Income Tax Officer, M/S Pharma Deal Agency, Ward No.8, Ward-1, Rewa, M.P. Mauganj, Distt. Rewa, M.P. Pan:Atrps5702K (Appellant) (Respondent)

For Appellant: Sh. Devendra Singh, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 143(2)Section 144Section 147Section 148Section 271(1)(b)Section 69A

which he requested that his earlier return filed on 19.11.2010 may be considered to be the return filed in response to notice under section 148. Thereafter, the ld. AO issued notices under section 143(2) / 142(1) asking the assessee to explain the issue. The ld. AO records that there

Rajesh Singh, Rewa vs. ITO Ward -1, Rewa

In the result, appeal in ITA No

ITA 128/JAB/2023[2010-11]Status: DisposedITAT Jabalpur19 Sept 2025AY 2010-11

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.128 & 129/Jab/2023 A.Y. 2010-11 Rajesh Singh, Vs. Income Tax Officer, M/S Pharma Deal Agency, Ward No.8, Ward-1, Rewa, M.P. Mauganj, Distt. Rewa, M.P. Pan:Atrps5702K (Appellant) (Respondent)

For Appellant: Sh. Devendra Singh, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR
Section 143(2)Section 144Section 147Section 148Section 271(1)(b)Section 69A

which he requested that his earlier return filed on 19.11.2010 may be considered to be the return filed in response to notice under section 148. Thereafter, the ld. AO issued notices under section 143(2) / 142(1) asking the assessee to explain the issue. The ld. AO records that there

Vikash Kumar, Patna vs. ITO, Ward- 6 (4), Patna

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

ITA 243/PAT/2025[2016-17]Status: DisposedITAT Patna19 Sept 2025AY 2016-17

Bench: This Tribunal. The Assessee Has Filed An Application Supported By An Affidavit, Explaining The Reasons For The Delay. After Considering The Submissions & Going Through The Petition, We Are Satisfied That The Assessee Was Prevented By Sufficient Cause In Filing The 2 Vikash Kumar Appeal Within The Prescribed Time. Accordingly, The Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 147Section 148Section 250

during the Financial Year 2015–16. The Assessing Officer initiated proceedings under section 147 of the Income-tax Act, 1961 and accordingly issued notice under section 148 of the Act. In response, the assessee filed return of income. During the course of assessment proceedings, the assessee sought reasons for reopening

Sanchit Kantilal Ganore, Bhagur vs. ITO Ward 1(1), Nashik

In the result, appeal of the assessee is partly allowed

ITA 1767/PUN/2025[2017-18]Status: DisposedITAT Pune19 Sept 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1767/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Sanchit Kantilal Ganore, V The Income Tax Officer, 21, Main Road, Bhagur, S. Ward-1(1), Nashik. Nashik - 422502. Pan: Aprpg4907J Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna Revenue By Shri Aviyogi Ambadkar– Add.Cit(Dr) Date Of Hearing 09/09/2025 Date Of Pronouncement 19/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2017-18, Dated 29.05.2025 Emanating From Assessment Order U/S.147 R.W.S 144 Of The I.T.Act, Dated 21.05.2023. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & In The Circumstances Of The Case & In Law & Without Prejudice To Other Grounds, Ld. Nfac Has Erred In Passing A

Section 147Section 148Section 149Section 151Section 250

learned Assessing Officer has erred in law and on facts in passing the assessment under section 147 of the Act and issuing notice under section 148 of the Act, without complying with the various jurisdictional preconditions and statutory safeguards under Income Tax Act, rendering the reassessment proceedings ... facts and in the circumstances of the case and without prejudice to any other grounds, the learned Assessing Officer has erred in issuing notice under section 148 of the Act in a standard format without striking off the inapplicable reasons or specifying the exact basis for reopening, thereby

Megnanapuram Paccs, Tiruchendur vs. PCIT, Madurai

ITA 895/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Sept 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:895/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Megnanapuram Primary Agricultural Co-Operative Credit Society 4/40, Megnanapuram Tiruchendur Road, Tiruchendur Thoothukudi – 628 210. [Pan: Aabam-9847-M] (अपीलार्थी/Appellant) Pcit Vs. Madurai - I (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 24.06.2025 घोषणा की तारीख/Date Of Pronouncement : 19.09.2025 आदेश /Order Per S. R. Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Pcit, Madurai - 1, For The Assessment Year 2018-19, Vide Order Dated 17.03.2025. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 147Section 148Section 263Section 80P

Section 80P of the Act to the tune of Rs.10,91,802/- forming part of the return of income filed in response to notice under Section 148 of the Act without assigning proper reasons and justification. 9) The PCIT failed to appreciate that there was complete scrutiny of facts referred

Phoenix Commodities Private Limited, Mumbai vs. ITO 3(2)(3), Mumbai, Aayakar Bhavan

In the result, grounds of appeal of

ITA 4730/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Sept 2025AY 2014-15

Bench: Shri Pawan Singh

Section 143(1)Section 147Section 148Section 254(1)

declaring Nil income. The return of income was processed under section 143(1). Thereafter, case of assessee was reopened under section 147. Notice under section 148 dated 30.03.2019 was served upon the assessee. Case of assessee was reopened on the basis of information from DDIT(Inv.), Unit – 6(3), Mumbai ... such information, the assessing officer has a reason to believe that taxable income in case of assessee has escaped assessment. In response to notice under section 148 filed its return of income on 15.04.2019 declaring Nil income. The assessing officer after serving reasons recorded proceeded for reassessment. The assessing officer

Phoenix Commodities Private Limited, Mumbai vs. ITO Ward 3(2)(4), Mumbai

In the result, grounds of appeal of

ITA 4729/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Sept 2025AY 2013-14

Bench: Shri Pawan Singh

Section 143(1)Section 147Section 148Section 254(1)

declaring Nil income. The return of income was processed under section 143(1). Thereafter, case of assessee was reopened under section 147. Notice under section 148 dated 30.03.2019 was served upon the assessee. Case of assessee was reopened on the basis of information from DDIT(Inv.), Unit – 6(3), Mumbai ... such information, the assessing officer has a reason to believe that taxable income in case of assessee has escaped assessment. In response to notice under section 148 filed its return of income on 15.04.2019 declaring Nil income. The assessing officer after serving reasons recorded proceeded for reassessment. The assessing officer

DCIT(CC)-8(3), Mumbai vs. Shapoorji Pallonji and Company Private Limited, Mumbai

The appeal of the revenue is dismissed on merits the various legal contentions in the C

ITA 2242/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Sept 2025AY 2012-13

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rajan Vora & Shri Nikhil
Section 115JSection 143(3)Section 147Section 151Section 250

currently pending before the Tribunal. In the mean time the assessee's case was reopened by issue of notice under section 148 dated 29.03.2019 for the reason that payments made by the assessee to one of the contractors i.e. Smt. Mayaben Vijay Parmar for manpower / labour services are unexplained

Krishna Enterprises, Delhi vs. ACIT Circle 34(1), Delhi

In the result, appeal of the assessee is allowed

ITA 5654/DEL/2024[2013-14]Status: DisposedITAT Delhi19 Sept 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] Krishna Enterprises, Assistant Commissioner Of 202, Bhagirathi Apartment, Income Tax, Sector-9, Rohini, Delhi- Vs Circle 34(1), 110085. Delhi. Pan- Aahfk4892P Assessee Revenue

Section 148Section 271(1)(c)Section 271BSection 44A

audited under Section 44AB of the Act. It is also noteworthy that the assessee did file his return of income only after a notice under Section 148 of the Act, which was issued to him. Thus, it is clear that the appellant is having a non-compliant and deliberate attitude