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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

Praveen Kumar Patwa HUF, Howrah vs. ITO, Ward-47(2), Kolkata

In the result, the appeal filed by the assessee is allowed on this issue

ITA 1333/KOL/2025[2015-16]Status: DisposedITAT Kolkata04 Sept 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1333/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2015-2016) Praveen Kumar Patwa Huf Vs Ito Ward-47 (2), Kolkata 12, Haradutta Ray Chamaria Rd Howrah, West Bengal-711101 Pan No. :Aajhp 7673 K (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By Shri Anil Kochar, Advocate रधजस्व की ओर से /Revenue By : Shri S.B.Chakraborthy, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/09/2025 घोषणा की तारीख/Date Of Pronouncement : 04/09/2025 आदेश / O R D E R Per Pradip Kumar Choubey, Jm : The Assessee Has Filed The Instant Appeal Against The Order Dated 23.05.2025, Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2015-2016. 2. The Sole Issue Involved In The Present Appeal Of The Assessee Is With Regard To Issuance Of Invalid Notice U/S.148 Of The Act Without Adhering To The New Inserted Provisions Of Section 148 R.W.S.148A Of The Act. 3. Ld. Ar Before Us Submitted That In This Case The Ao Has Framed The Assessment U/S.147 R.W.S.144 Of The Act Assessing The Total Income Of The Assessee At Rs.59,77,593/- Thereby Making Addition U/S.68 Of The Act At Rs.36,09,222/- & Addition Made U/S.69C Of The Act At Rs.1,80,461/-. In Appeal, The Ld.Cit(A) Dismissed The Appeal Of The Assessee. It Has Also Been Submitted By The Ld.Ar That Both The Authorities Below Have Erred In Not Considering The Fact That The Notice Issued U/S.148 Of The Act Is Invalid & Bad In Law As The Notice In This Case Has Been Issued On 01.04.2021

For Respondent: Shri S.B.Chakraborthy, Sr. DR
Section 147Section 148Section 148ASection 68Section 69C

under :- Heard learned advocates appearing for the respective parties. Petitioner in this writ petition is aggrieved by the issuance of impugned notice under section 148 of the Income Tax Act, 1961 on the grounds that the same is barred by limitation and that the respondent-income tax authority concerned, before ... issuing the impugned notices under section 148 of the 1961 Act, has not observed the statutory formalities under section 148A of the 1961 Act as prescribed by the Finance Act, 2021 which are applicable with effect from 1st April 2021 before issuance of notices under section 148

Mrs. Roopa Rathi, Chennai vs. ITO, Ncw-10(3), Chennai

In the result, the appeal of the assessee is allowed

ITA 1707/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Sept 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1707/Chny/2025 Assessment Years: 2018-19 Mrs.Roopa Rathi, Income Tax Officer, Door No.1, Damodar Murthy Street, Non-Corporate Ward-10(3), Kilpauk, Chennai. Chennai-600 010. [Pan: Ajapr6077R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.Hitesh, Advocate For Mr.D.Anand, Advocate. प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 25.08.2025 घोषणा की तारीख /Date Of Pronouncement : 04.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.Hitesh, Advocate for Mr.D.AnandFor Respondent: Ms.Gouthami Manivasagam, JCIT
Section 147Section 148Section 148ASection 151Section 151ASection 68

purpose of this Scheme,–– Page - 4 - of 9 (a) assessment, reassessment or recomputation under section 147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148

Deputy Commissioner of Income Tax, Salem vs. Govinda Rajulu Srinivasan, Salem

In the result, appeal of the Revenue stands dismissed

ITA 1245/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Sept 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Bhupendran, AdvocateFor Respondent: Mrs.C. Yamuna, CIT
Section 147Section 148Section 40Section 40A(3)

assessment or reassessment of escaped income, and which he intends to take into account, he would be required to issue a fresh notice under Section 148 of Act. Thus, it was held that the Assessing Officer had. jurisdiction to reassess the income other than the income in respect of which

Jayaraman Rudrasekar, Vellore vs. DCIT, Central Circle-1(4), Chennai

In the result, appeal filed by the assessee is allowed

ITA 1142/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Sept 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.N. Arjun Raj, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 151Section 151A

आयकर अपीलीय अिधकरण, ’सी’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक

Razaq Liyakhath Ali, Channagiri vs. ITO-Ward-2(1) Davanagere, Davanagere

In the result, appeal filed by the assessee is dismissed

ITA 1339/BANG/2025[2017-18]Status: DisposedITAT Bangalore04 Sept 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Razaq Liyakhath Ali, Vs. Ito, Kouzer Masjid Circle Fort Road, Ward – 2(1), Channagiri, Davangere. Davangere – 577 213. Pan : Acepl 3149 D Appellant Respondent Assessee By : Shri. Sachin, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 01.09.2025 Date Of Pronouncement : 04.09.2025

For Appellant: Shri. Sachin, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 139(1)Section 142(1)Section 148Section 271BSection 273BSection 44A

name and style of A. R. Timber at NS13, Main Road, Chennagiri – 577213, Davangere, Karnataka. The case was reopened after issue of notice under section 148 of the Act and the assessee filed return of income. It was noted that the assessee did not file his return of income

ITO-34.2.1, Mumbai vs. Mangal Suresh Karkhanis, Mumbai

In the result, the appeal filed by the Revenue is,

ITA 486/MUM/2025[2016]Status: DisposedITAT Mumbai04 Sept 2025
Section 147Section 148Section 148ASection 151

could be reopened within six years from the end of the relevant assessment year. Thus, the period for reopening culminated on 31.03.2023. The notice under section 148 was in fact issued on 13.05.2021, i.e., within limitation. Therefore, the assessee raised no grievance as to limitation. However, since the reopening ... Mumbai, who had no jurisdiction to do so. Accordingly, it was contended that the order under section 148A(d) and the notice under section 148 are vitiated ab initio. 4. In this regard, the Ld. AR drew attention to the substituted provisions of section 151, effective from 01.04.2021, reproduced

Satya Enterprises, Bilaspur vs. Income Tax Officer, Ward-1(2), Bilaspur

In the result, appeal of the assessee is allowed

ITA 396/RPR/2025[2017-18]Status: DisposedITAT Raipur03 Sept 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.396/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Satya Enterprises Ward No.3, Shanti Nagar, Bilaspur (C.G.)-495 001 Pan: Adcfs1415L .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 144Section 148Section 292B

which the assessee informed the Assessing Officer that the return originally filed should be treated as the return filed pursuant to the notice under section 148 of the Act. 13. In DIT v. Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated ... escaped liability, shall serve notice specifying particulars of such claim. In view of the above, after receipt of return in response to notice under section 148, it shall be mandatory for the Assessing Officer to serve a notice under sub-section (2) of section 143 assigning reason therein...in absence

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 186/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR
Section 119Section 142(1)Section 147Section 148Section 69A

notice. The date and time of the approval granted digitally under section 151 of the Act and the date and time of the notice under section 148 of the Act, shows that the satisfaction was recorded by the PCTT digitally after the notice under section 148 was digitally signed ... when the Assessing Officer issued notice to the assessees under section 148 of the Act, 1961. At the time when the notice under section 148 of the Act, 1961 was issued by the Assessing Officer to the petitioner there was no valid satisfaction recorded by the Prescribed Authority

Ms Aditya Plastic, Rajkot vs. The Income Tax Officer, Ward 3(1)(1), Rajkot-

In the result, the appeal of the assessee is allowed

ITA 185/RJT/2024[2013-14]Status: DisposedITAT Rajkot03 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR
Section 119Section 142(1)Section 147Section 148Section 69A

notice. The date and time of the approval granted digitally under section 151 of the Act and the date and time of the notice under section 148 of the Act, shows that the satisfaction was recorded by the PCTT digitally after the notice under section 148 was digitally signed ... when the Assessing Officer issued notice to the assessees under section 148 of the Act, 1961. At the time when the notice under section 148 of the Act, 1961 was issued by the Assessing Officer to the petitioner there was no valid satisfaction recorded by the Prescribed Authority

Nandigam Veerabrahmam, Rajahmundry vs. Income Tax Officer, Ward-2(1), Rajahmundry

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 271/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam03 Sept 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148A

purposes of this section, specified authority means the specified authority referred to in section 151.” Conducting inquiry, providing opportunity before issue of notice under section 148- “148A. The Assessing Officer shall, before issuing any notice under section 148,— (a) conduct any enquiry, if required, with the prior approval of specified ... issued, or such time, as may be extended by him on the basis of an application in this behalf, as to why a notice under section 148 should not be issued on the basis of information which suggests that income chargeable to tax has escaped assessment in his case

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 91/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh03 Sept 2025AY 2018-19

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

still be some reasons which warrant holding belief that income chargeable to tax has escaped assessment so as to necessitate issuance of a notice under section 148 - Held, yes - Assessing Officer referred matter to DVO for determining cost of construction of project of assessee and based upon report

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 90/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh03 Sept 2025AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

still be some reasons which warrant holding belief that income chargeable to tax has escaped assessment so as to necessitate issuance of a notice under section 148 - Held, yes - Assessing Officer referred matter to DVO for determining cost of construction of project of assessee and based upon report

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 127/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh03 Sept 2025AY 2016-17

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 127, 90 & 91 /Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2016-17, 2017-18 & 2018-19 AFI Feed Industries Shop No. 13, Khanna City Centre, G.T. Road, Ground Floor, Bolck-C, Khanna, Punjab-141401 स्थायी लेखा सं./PAN NO: ABDFA5916B अपीलार्थी/Appellant निर्धारिती की ओर से/Assessee by : राजस्व की ओर से / Revenue by : बनाम The DCIT Central Circle-l Ludhiana प्रत्यर्थी / Respondent Shri Ashwani Kumar, Ms. Deepali

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

still be some reasons which warrant holding belief that income chargeable to tax has escaped assessment so as to necessitate issuance of a notice under section 148 - Held, yes - Assessing Officer referred matter to DVO for determining cost of construction of project of assessee and based upon report

Evexia Lifecare Limited, Vadodara vs. The ITO, Ward-1(1)(1), Vadodara

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

ITA 605/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Sept 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 147Section 148

basis of this information, the case of the assessee was reopened under Section 147 of the Act to examine these transactions and a notice under Section 148 of the Act was issued on 31.03.2022. In the course of assessment, the assessee had explained that these transactions were on account

Dilipkumar Sohanlal Maheshwari, Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 29/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad03 Sept 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2015-16

Section 10(38)Section 142Section 143Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 68

from the Investigation wing that the assessee was a beneficiary of penny stock investment in the shares of M/s. Vandana Knitwear. Therefore, a notice under Section 148 of the Act was issued by the Assessing Officer on 31.03.2021 after recording the reasons. In the course of assessment, the assessee

M/S Lorgan Lifestyle Ltd., Pune vs. ITO, Ward14(4), Pune

In the result, appeal of the assessee is allowed as per terms indicated above

ITA 215/PUN/2025[2015-16]Status: DisposedITAT Pune03 Sept 2025AY 2015-16

Bench: Dr.Manish Borad & Ms.Astha Chandra

For Appellant: Shri B S RajpurohitFor Respondent: Shri Amol Khairnar
Section 143(3)Section 250

case of Jet Airways (I) Ltd. (supra) comes to the rescue of the assessee wherein it was held that “if after issuing a notice under section 148, he (AO) accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe ... escaped assessment, it is not open to him independently to assess some other income. If he intends to do so, a fresh notice under section 148 would be necessary, the legality of which would be tested in the event of a challenge by the assessee”. Considering the judgment

Vishal Vijay Jaiswal, Jalgaon vs. ITO Ward 2(1), Jalgaon

In the result, appeal of the assessee is allowed

ITA 1634/PUN/2025[2017-18]Status: DisposedITAT Pune03 Sept 2025AY 2017-18

Bench: Dr.Manish Borad

For Appellant: Shri Vinay KawadiaFor Respondent: Shri Sanjay Dhivare
Section 147Section 148Section 148ASection 151Section 250

have been raised but one of the primary grounds for challenging the notice under 4 Vishal Vijay Jaiswal section 148A(d) and the notice under section 148 of the Act both dated 7th April 2022 is that order as well as the notice both mention the authority that has granted ... decision of Hon’ble Bombay High Court(supra) and ITAT Pune (supra), the order under Section 148A(d) of the Act, and notice under section 148 are quashed. Accordingly, the legal ground raised by the assessee is allowed. We have already mentioned that both parties only argued on the legal

Ekambaram Elumalai, Chennai vs. ITO, Ncw-19(4), Chennai

ITA 1799/CHNY/2025[2017-18]Status: DisposedITAT Chennai03 Sept 2025AY 2017-18

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Amitabh Shuklaekambaram Elumalai आयकर अपील सं./Ita No.1799/Chny/2025

For Appellant: Shri S.Sridhar, AdvocateFor Respondent: Shri Veeramany K, IRS
Section 147Section 148Section 69A

Scheme.—For the purpose of this Scheme, — (a) assessment, reassessment or recomputation under section 147 of the Act, (b) issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148

Muthu Palaniappan, Trichy vs. ACIT, Ncc-3(1), Chennai

In the result, the appeal filed by the assessee is partly allowed

ITA 1623/CHNY/2025[2017-18]Status: DisposedITAT Chennai03 Sept 2025AY 2017-18

Bench: Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.1623/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Muthu Palaniappan, Vs. The Assistant Commissioner Of C/O Palaniyappa Bros., Nsb Road, Income Tax, Trichy 620 002. Non Corporate Circle 3(1), Chennai. [Pan:Atzpp2653E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Girish Kumar, Advocate ""थ" की ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई की तारीख/ Date Of Hearing : 01.09.2025 घोषणा की तारीख /Date Of Pronouncement : 03.09.2025 आदेश /O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 10 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Additions Made By The Assessing Officer Disallowing The Interest Claimed By The Assessee.

For Appellant: Shri Girish Kumar, AdvocateFor Respondent: Ms. V. Aswathy, JCIT
Section 148

firms and deposits with firms. The assessee filed his return of income admitting an income of ₹.20,54,370/- in response to the notice under section 148 of the Income Tax Act, 1961 [“Act” in short]. The admitted income includes income from house property of ₹.16,16,607/- and income

Star Ceramics, Chitradurga vs. Income Tax Officer, Ward-1, Chitradurga

In the result, the appeal of the assessee is allowed

ITA 1064/BANG/2025[2016-17]Status: DisposedITAT Bangalore03 Sept 2025AY 2016-17

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

For Appellant: Ms. Richa Bakiwala & Shri Hemasundar Rao P., CAsFor Respondent: Shri Thamba Mahendra, CIT(DR)(ITAT), Bengaluru
Section 147Section 148Section 148ASection 68Section 69A

proceedings were initiated based on vague, borrowed, and unverified information, and without independent application of mind by the learned Assessing Officer. IV The notice under Section 148 and the order under Section 148A(d), issued after April 1, 2021, are invalid as the amended provisions of Sections ... Chief Commissioner of Income Tax, not the Principal Commissioner of Income Tax. V The order issued under Section 148A(d) and the subsequent notice under Section 148 of the Act, issued by the Jurisdictional Assessing Officer instead of the Faceless Assessment Unit, is legally invalid. VI The manual notice issued