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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

Santosh Rani Legal Heir of Late Sh Parveen Kalyan, Kurukshetra vs. Income Tax Officer, Ward 1, Karnal

In the result, appeal of the assessee is allowed

ITA 4770/DEL/2024[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2011-12] Santosh Rani Vs Ito, Legal Heir Of Late Shri Parveen Ward-1, Karnal, Kalyan, Krishna Nagar, Gamri, Haryana-132001. Thanesar, Distt.-Kurukshetra, Haryana-136118. Pan-Awhpr4944D Appellant Respondent Appellant By Shri Suresh K.Gupta, Ca Respondent By Shri Dheeraj Kumar Jaiswal, Sr.Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 19.09.2025 Order

Section 144Section 147Section 148Section 151Section 250

impugned order held that where Joint Commissioner recorded satisfaction in mechanical manner and without application of mind to accord sanction for issuing notice under. section 148, reopening of assessment was invalid - Whether Special Leave Petition filed against impugned order was to be dismissed - Held, yes [In favour of assessee] Search ... Commissioner of Income-tax, with the following remarks: "Yes, I am satisfied with the reasons recorded by the Assessing Officer for issuance of notice under section 148 of the Income- tax Act, 1961." (emphasis¹ supplied) 23. The power to sanction reassessment under section 151, is coupled with a duty

Arun Duggal, Faridabad vs. DCIT, Central Circle- 1, Faridabad

In the result, appeal of the assessee is partly allowed

ITA 3075/DEL/2018[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2009-10] Arun Duggal, Vs Dcit, 3E-42, Nit, Faridabad, Central Circle-1, Haryana-121001. Faridabad. Pan-Agupd5708Q Appellant Respondent Appellant By Dr. Kapil Goel, Adv. Respondent By Shri Pravin Rawal, Cit Dr Date Of Hearing 26.06.2025 Date Of Pronouncement 19.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 26.02.2018 Passed By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.617/Cit(A)-3/Ggn/2016-17 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 23.12.2016 Passed U/S 147 R.W.S. 143(3) Of The Act Pertaining To Assessment Year 2009-10. 2. Brief Facts Of The Case Are That The Appeal Of The Assessee Was Heard By The Co-Ordinate “E” Bench Of The Tribunal & Was Decided In Terms Of Order Dated 01.04.2022 Wherein Co-Ordinate Bench Has Dismissed The Appeal Of The Assessee. Thereafter, Assessee Filed Miscellaneous Application (M.A.) Bearing No.100/Del/2022 U/S 254(2) Of The Act. The Co-Ordinate Bench Vide Its Order Dated 09.04.2025 Has Decided The M.A. Filed By Assessee Wherein Order Of Co-Ordinate Bench Dated 04.01.2022 Is Recalled For The Limited Purposes Of Adjudication Of Three Grounds Of Appeal Taken In The Original Form 36. These Grounds Of Appeal Are Bearing Nos.1.2, 1.8 & 5. The Relevant Observations Of The Co-Ordinate Bench In Para 16 Of The Order Of Ma Are As Under:-

Section 147Section 151Section 250Section 254(2)Section 68

impugned order held that where Joint Commissioner recorded satisfaction in mechanical manner and without application of mind to accord sanction for issuing notice under. section 148, reopening of assessment was invalid - Whether Special Leave Petition filed against impugned order was to be dismissed - Held, yes [In favour of assessee] Search ... Commissioner of Income-tax, with the following remarks: "Yes, I am satisfied with the reasons recorded by the Assessing Officer for issuance of notice under section 148 of the Income-tax Act, 1961." (emphasis¹ supplied) 23. The power to sanction reassessment under section 151, is coupled with a duty

DCIT, New Delhi vs. Newbury Holding Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 5335/DEL/2015[2008-09]Status: DisposedITAT Delhi19 Sept 2025AY 2008-09

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

Assessing Officer. 5. The ld. Commissioner of Income Tax (Appeals) has erred in holding that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act by wrongly holding that the assessee company was a non-resident entity. 6. The Ld. Commissioner of Income Tax (Appeals

DCIT, New Delhi vs. Newbury Holding Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 5334/DEL/2015[2007-08]Status: DisposedITAT Delhi19 Sept 2025AY 2007-08

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

Assessing Officer. 5. The ld. Commissioner of Income Tax (Appeals) has erred in holding that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act by wrongly holding that the assessee company was a non-resident entity. 6. The Ld. Commissioner of Income Tax (Appeals

DCIT, New Delhi vs. Eicr (Cyprus) Ltd., New Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 5333/DEL/2015[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

Cyprus) Ltd. 5. The ld. Commissioner of Income Tax (Appeals) has erred in holding that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act by wrongly holding that the assessee company was a non-resident entity. 6. The Ld. Commissioner of Income Tax (Appeals

DCIT, New Delhi vs. Eicr (Cyprus) Ltd., New Delhi

ITA 5332/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Sept 2025AY 2010-11

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 124(4)Section 132Section 144CSection 147Section 148Section 151Section 6(3)(ii)

Assessing Officer. 5. The ld. Commissioner of Income Tax (Appeals) has erred in holding that the Assessing Officer had no jurisdiction to issue notice under section 148 of the Act by wrongly holding that the assessee company was a non-resident entity. 6. The Ld. Commissioner of Income Tax (Appeals

Musaddilal Mansaram Infrastructure Pvt. Ltd., Bilaspur vs. Income Tax Officer, Ward-1(1), Bilaspur

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

ITA 160/RPR/2025[2015-16]Status: DisposedITAT Raipur18 Sept 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 149Section 149(1)(a)Section 151Section 153CSection 50C(2)Section 56(2)(vii)

that if the Department has al chosen not to proceed under Section 153C, no right is created to the petitioner for getting the notice under Section 148 quashed. Moreover, learned Single Judge was not having the benefit of the decision of the Supreme Court in the case of Abhisar Buildwell ... Saloni Prakash Kumar (supra) is of no help to the respondents. The High Court held that Section 153C does not preclude issuance of notice under Section 148. The field of applicability of two sections was not the issue before the Court. 7. Ld. AR further drew our attention

Income Tax Officer-1(1), Bilaspur vs. Musaddilal Mansaram Infrastructure Pvt. Ltd., Bilaspur

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

ITA 153/RPR/2025[2015-16]Status: DisposedITAT Raipur18 Sept 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 149Section 149(1)(a)Section 151Section 153CSection 50C(2)Section 56(2)(vii)

that if the Department has al chosen not to proceed under Section 153C, no right is created to the petitioner for getting the notice under Section 148 quashed. Moreover, learned Single Judge was not having the benefit of the decision of the Supreme Court in the case of Abhisar Buildwell ... Saloni Prakash Kumar (supra) is of no help to the respondents. The High Court held that Section 153C does not preclude issuance of notice under Section 148. The field of applicability of two sections was not the issue before the Court. 7. Ld. AR further drew our attention

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 772/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

admitting the matter framed the following question of law: "(i) Whether the learned Income-tax Appellate Tribunal was right in holding that the notice under section 148 dated March 22, 2010 having been sent through speed post and not having been received back, there was a presumption ... challenging the validity of reasons recorded for initiating proceedings under section 148 of the Act. (i) First letter challenging the service of notice under section 148 is dealt with as under: For the sake of convenience and ready reference, the assessee's letter is reproduced as under: 4 On March

Sh. Hari Prakash Gupta, Jaipur vs. ITO, Ward-1(2), Jaipur

The appeal stands allowed

ITA 771/JPR/2025[2010-11]Status: DisposedITAT Jaipur18 Sept 2025AY 2010-11
For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 271(1)(c)Section 37(1)Section 44A

admitting the matter framed the following question of law: "(i) Whether the learned Income-tax Appellate Tribunal was right in holding that the notice under section 148 dated March 22, 2010 having been sent through speed post and not having been received back, there was a presumption ... challenging the validity of reasons recorded for initiating proceedings under section 148 of the Act. (i) First letter challenging the service of notice under section 148 is dealt with as under: For the sake of convenience and ready reference, the assessee's letter is reproduced as under: 4 On March

Mo. Shariph Kureshi, Sikar vs. ITO Ward-4 Sikar, Sikar

In the result, the appeal of the assessee is allowed

ITA 366/JPR/2025[2013-14]Status: DisposedITAT Jaipur18 Sept 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 234ASection 271(1)(c)

notice subsequently in the course of the proceedings under the section as having escaped assessment. If upon the issuance of a notice under section 148(2), the Assessing Officer accepts the objections of the assessee and does not assess or reassess the income which was the basis of the notice ... facts of the case were as under- “After processing of return under section 143(1) of the Act, the Assessing Officer issued notice under section 148 of the Act seeking to reopen the assessment of the assessee on the ground that capital subsidy was 17 Mo. Shariph Kureshi, Sikar. outstanding

Nikulbhai Chaturbhai Patel, HUF, Gandhinagar vs. The ITO, Ward-4(2)(3), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 47/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

assessment was completed under section 143(3) of the Act on 14.12.2016, accepting the returned income of Rs. 9,33,446/-. The reassessment notice under section 148 of the Act was admittedly issued beyond four years from the end of the relevant assessment year. Therefore, the provisions of the first ... ICICI Bank account. This led to the reopening of the case under Section 147 of the Income Tax Act, and a notice under Section 148 was issued on 31.03.2021. In response, the assessee filed a revised return on 30.09.2021. The reasons for reopening, as provided to the assessee, indicated suspicion

Nikulbhai Chaturbhai Patel, HUF, Gandhinagar vs. The ITO, Ward-4(2)(3), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 46/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2015-16

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

assessment was completed under section 143(3) of the Act on 14.12.2016, accepting the returned income of Rs. 9,33,446/-. The reassessment notice under section 148 of the Act was admittedly issued beyond four years from the end of the relevant assessment year. Therefore, the provisions of the first ... ICICI Bank account. This led to the reopening of the case under Section 147 of the Income Tax Act, and a notice under Section 148 was issued on 31.03.2021. In response, the assessee filed a revised return on 30.09.2021. The reasons for reopening, as provided to the assessee, indicated suspicion

Nikulbhai Chaturbhai Patel, HUF, Gandhinagar vs. The ITO, Ward-4(2)(3), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 45/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

assessment was completed under section 143(3) of the Act on 14.12.2016, accepting the returned income of Rs. 9,33,446/-. The reassessment notice under section 148 of the Act was admittedly issued beyond four years from the end of the relevant assessment year. Therefore, the provisions of the first ... ICICI Bank account. This led to the reopening of the case under Section 147 of the Income Tax Act, and a notice under Section 148 was issued on 31.03.2021. In response, the assessee filed a revised return on 30.09.2021. The reasons for reopening, as provided to the assessee, indicated suspicion

Income Tax Ward 4(2)(3) Ahmedabad, Ahmedabad vs. Nikulbhai Chaturbhai Patel HUF, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 267/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

assessment was completed under section 143(3) of the Act on 14.12.2016, accepting the returned income of Rs. 9,33,446/-. The reassessment notice under section 148 of the Act was admittedly issued beyond four years from the end of the relevant assessment year. Therefore, the provisions of the first ... ICICI Bank account. This led to the reopening of the case under Section 147 of the Income Tax Act, and a notice under Section 148 was issued on 31.03.2021. In response, the assessee filed a revised return on 30.09.2021. The reasons for reopening, as provided to the assessee, indicated suspicion

Income Tax Ward 4(2)(3) Ahmedabad, Ahmedabad vs. Nikulbhai Chaturbhai Patel HUF, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 266/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT-DR & Shri HargovindFor Respondent: Shri Rignesh Das, CIT-DR & Shri Hargovind
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68Section 69

assessment was completed under section 143(3) of the Act on 14.12.2016, accepting the returned income of Rs. 9,33,446/-. The reassessment notice under section 148 of the Act was admittedly issued beyond four years from the end of the relevant assessment year. Therefore, the provisions of the first ... ICICI Bank account. This led to the reopening of the case under Section 147 of the Income Tax Act, and a notice under Section 148 was issued on 31.03.2021. In response, the assessee filed a revised return on 30.09.2021. The reasons for reopening, as provided to the assessee, indicated suspicion

Sanjay Kumar Bhutra, Kolkata vs. ITO, Ward 44(2), Kolkata

In the result, all the appeals of the Revenue are dismissed

ITA 261/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Sept 2025AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2013-14 Sanjay Kumar Bhutra………...……………………….……….……….……Appellant Geeta Katra, 1, Mullick St., 1St Floor, Burrabazar, Kol- 7.. [Pan: Ahspb7216J] Vs. Ito, Ward-44(2), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri S. K. Pransukha, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 04, 2025 Date Of Pronouncing The Order : September 18, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 19.12.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

Section 148Section 148ASection 149Section 250Section 3(1)

TOLA apply "notwithstanding anything contained in the specified Act." Section 3(1), therefore, overrides the time limits for issuing a notice under Section 148 read with Section 149 of the Income Tax Act; d. TOLA does not extend the life of the old regime. It merely provides a relaxation ... Revenue between 1 April 2021 and 30 June 2021 as show- cause notices in terms of Section 148A(b). Thereafter, the Revenue issued notices under Section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground

Sulochana Devi Bagaria, Kolkata vs. ITO, Ward 44(2), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1211/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Sept 2025AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1208 To 1211/Kol/2025 Assessment Year: 2015-16 Sulochana Devi Bagaria..……………………………………….……….……Appellant 200, Bangur Avenue, Block-A, Kol-700055. [Pan: Aebpb4214J] Vs. Ito, Ward-44(2), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Anil Kochar, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 11, 2025 Date Of Pronouncing The Order : September 18, 2025 Order Per Pradip Kumar Choubey:

Section 148Section 250

perused the material available on record. It is an undisputed fact that the deceased assessee Manju Goel died on 31.01.2021 and admittedly the notice under section 148 was issued on 31.03.2021. Therefore, admittedly the proceedings were initiated under section 148 of the Act for reassessment relating to escapement of income

Sulochana Devi Bagaria, Kolkata vs. ITO, Ward 44(2), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1210/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Sept 2025AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1208 To 1211/Kol/2025 Assessment Year: 2015-16 Sulochana Devi Bagaria..……………………………………….……….……Appellant 200, Bangur Avenue, Block-A, Kol-700055. [Pan: Aebpb4214J] Vs. Ito, Ward-44(2), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Anil Kochar, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 11, 2025 Date Of Pronouncing The Order : September 18, 2025 Order Per Pradip Kumar Choubey:

Section 148Section 250

perused the material available on record. It is an undisputed fact that the deceased assessee Manju Goel died on 31.01.2021 and admittedly the notice under section 148 was issued on 31.03.2021. Therefore, admittedly the proceedings were initiated under section 148 of the Act for reassessment relating to escapement of income

Sulochana Devi Bagaria, Kolkata vs. ITO, Ward 44(2), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1209/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Sept 2025AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1208 To 1211/Kol/2025 Assessment Year: 2015-16 Sulochana Devi Bagaria..……………………………………….……….……Appellant 200, Bangur Avenue, Block-A, Kol-700055. [Pan: Aebpb4214J] Vs. Ito, Ward-44(2), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Anil Kochar, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 11, 2025 Date Of Pronouncing The Order : September 18, 2025 Order Per Pradip Kumar Choubey:

Section 148Section 250

perused the material available on record. It is an undisputed fact that the deceased assessee Manju Goel died on 31.01.2021 and admittedly the notice under section 148 was issued on 31.03.2021. Therefore, admittedly the proceedings were initiated under section 148 of the Act for reassessment relating to escapement of income