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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

Sapana Rajendra Kumar Marathe, Mumbai vs. ITO Ward 23(3)(1), Mumbai

Appeal of the assessee is allowed

ITA 4363/MUM/2025[2015-16]Status: DisposedITAT Mumbai03 Sept 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, Sr. DR
Section 147Section 148Section 148ASection 250Section 69A

lieu of her old flat. Since the assessee has not offered the monetary consideration received, the AO reopened the assessment by issue of notice under section 148 of the Act between 01.04.2021 to 30.06.2021. In view of the decision of the Hon'ble Supreme Court in the case of Union ... said notice. Since the assessee did not respond the AO passed an order under section 148A(d) and also issued a notice under section 148 on 16.07.2022. The AO completed the assessment under section 147 r.w.s. 144 of the Act i.e. ex-parte for the reason that the assessee

Gupta Builders and Developers, Mumbai vs. Asst. Commissioner of Income Tax Central Circle 4(3), Mumbai

Appeal of the assessee is allowed

ITA 4361/MUM/2025[2015-16]Status: DisposedITAT Mumbai03 Sept 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Ms. Ritika Agarwal, Advocate
Section 133ASection 143(1)Section 148Section 148ASection 151Section 250Section 68

dismissed the appeal of the assessee. Before the CIT(A) the assessee raised a legal contention stating that the notice under section 148 dated 31.03.2021 was issued on 01.04.2021 and that the AO did not follow the procedure as per the directions of the Hon'ble Supreme Court ... condone the delay of 183 days in filing the appeal and admit the appeal for adjudication. 5. The ld. AR submitted that the notice under section 148 dated 31.03.2021 was actually served on the assessee through email only on 01.04.2021. In this regard the ld. AR drew our attention

Aggarwal Abhushan Private Limited, Delhi vs. DCIT Circle 1(1), Delhi/National Faceless Appeal Centre Delhi, New Delhi

In the result, the appeal of the assessee is allowed

ITA 712/DEL/2025[2016-17]Status: DisposedITAT Delhi03 Sept 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Sudhir Kumaraggarwal Abhushan Vs. Dcit Circle-1(1), Delhi/ Private Limited, National Faceless Appeal B-5/153, Sector-7, Centre, Delhi-110002 Rohini, Delhi-110085

For Appellant: Ms. Meenal Goyal, Adv. &For Respondent: Shri Om Prakash, Sr. DR
Section 147Section 148Section 148ASection 149

this proposition, the Learned AR placed on record the table containing the list of dates and events as under:- A. Date of original notice under section 148 30-6-2021 B. Date of decision of Hon’ble Supreme Court in the case of Ashish Agarwal reported ... said order is reproduced herein below:- “65. Thus, in the facts of the present case, the last date for issuance of notice under Section 148 of the Act for AY 2013-14 under the statutory framework, as was existing prior to 01.04.2021 was 31.03.2020, that is, six years from

DCIT, Delhi vs. Majestic Properties Private Limited, Delhi

ITA 2129/DEL/2025[2012]Status: HeardITAT Delhi03 Sept 2025

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshdcit, Circle-16(1) Vs. Majestic Properties Room No.419, Private Limited, Fourth Floor, C.R. 1/18 B, Asaf Ali Road, Building Ip Estate, Ajmeri Gate Extn. Delhi-110002 Delhi-110002 (Appellant) (Respondent) Pan: Aaacm7158E

For Appellant: NoneFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 115JSection 139(1)Section 143(3)Section 147Section 148Section 151Section 45(2)

assessee was reopened under section 147 of the Act after duly recording the reasons for reopening the assessment for assessment year 2012-13. Notice under section 148 of the Act stood issued to the assessee on 28.3.2019 after taking prior approval or sanction of the competent authority under section ... vide letter dated 13.12.2019 submitted that the return already filed under section 139(1) may be considered as a return in response to notice under section 148 of the Act. The learned AO noted that

Ap Goyal Charitable Trust, East Delhi, Delhi India vs. ITO, Civic Centre, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1941/DEL/2025[2014-15]Status: HeardITAT Delhi03 Sept 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshap Goyal Charitable Trust, Vs. Ito, Ward B-125, Anand Vihar, Exempt-1(1), East Delhi, Delhi-110092 Delhi, Civic Centre, Delhi-110002 (Appellant) (Respondent) Pan: Aabta8575B

For Appellant: Shri Nitin Kanwar, AdvocateFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 12ASection 132Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 151

case of Anandilal & Ganesh Podar Society, M/s Podar Education Trust and M/s Podar Education & Sports Trust. The Jurisdictional Assessing Officer issued first notice under section 148 of the Act on 28-06-2021. The assessee filed Writ Petition in WP(C ) 9379 / 2021 before the Hon’ble Delhi High Court ... filed by the assessee along with others, restraining the revenue from continuing with the reassessment proceedings in any manner pursuant to the aforesaid notice under section 148 of the Act. On 21- 03-2022, the assessee submitted its reply before the learned AO in response to show cause notice issued

Edynamics Solutions Limited, Laxmi Nagar vs. Assessing Officer Ward 8 (1), Cr Building ITO

In the result the appeal is dismissed

ITA 1391/DEL/2024[AY 2012-13]Status: DisposedITAT Delhi03 Sept 2025

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2012-13 Edynamics Solutions Limited, Vs. Assessing Officer, 103 First Floor, Plot No.2, Ward 8(1), Tiriveni Complex, Veer Savarkar Delhi Block, Shakarpur, City, Pin: 1100 02 New Delhi-1100 92 Pan :Aaace7849N (Appellant) (Respondent)

Section 143(2)Section 147Section 148Section 250Section 251

under Section 147 of the Act were initiated in the case of assessee by recording reasons and satisfaction that income has escaped assessment. Notice under Section 148 of the Act was issued on 31.03.2019. Notice under Section 143(2) of the Act along with questionnaire were issued on different dates

DCIT Central Circle 1(1) Ahmedabad, Ahmedabad vs. Mahendrakumar Chunilal Sanghvi, Ahmedabad

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

ITA 1351/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2021-22

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 149Section 69C

under Rs. 50 lakhs. However, it is contended that the same would not preclude the AO from issuing a notice under Section 148 of the Act as cumulatively the income that is alleged to have escaped assessment is to the extent of 0.73 crores which is in excess ... relevant extract of Section 149 of the Act is set out below: "149. Time limit for notice. - (1) No notice under section 148 shall be issued for the relevant assessment year,— (a) if three years have elapsed from the end of the relevant assessment year, unless the case falls under

Mahendrakumar Chunilal Sanghvi, Mumbai vs. DCIT CC 1(1) Ahmedabad, Ahmedabad

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

ITA 1267/AHD/2024[2017-2018]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2017-2018

Bench: or at the time of hearing of the appeal."

Section 147Section 148Section 148ASection 149Section 69C

under Rs. 50 lakhs. However, it is contended that the same would not preclude the AO from issuing a notice under Section 148 of the Act as cumulatively the income that is alleged to have escaped assessment is to the extent of 0.73 crores which is in excess ... relevant extract of Section 149 of the Act is set out below: "149. Time limit for notice. - (1) No notice under section 148 shall be issued for the relevant assessment year,— (a) if three years have elapsed from the end of the relevant assessment year, unless the case falls under

Pradeep Jeyavelu, Tiruvallur vs. ITO, Ward-1, Tiruvallur

ITA 1626/CHNY/2025[2016-17]Status: DisposedITAT Chennai02 Sept 2025AY 2016-17

Bench: Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.1626/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Pradeep Jeyavelu, Vs. The Income Tax Officer, No. 2/697 Balaji Nagar Thiruyur Ward 1, Kuppam, Sevvapettai, Tiruvallur. Tiruvallur 602 025. [Pan:Bblpj4017P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R.S. Hithesh, 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 22.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. The Assessee Raised 9 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer On Account Of Long Term Capital Gain.

For Appellant: Shri R.S. Hithesh, AdvocateFor Respondent: Ms. V. Aswathy, JCIT
Section 148Section 54

that the assessee is an individual, filed return of income on 28.03.2023 declaring total income of ₹.13,91,143/- in response to the notice under section 148 of the Income Tax Act, 1961 [“Act” in short]. It is noticed that the Assessing Officer asked the assessee to furnish details

Ganpat Ram Singhal, New Delhi vs. ACIT, Circle 25(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2054/DEL/2023[2011-12]Status: DisposedITAT Delhi02 Sept 2025AY 2011-12

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Pranav Yadav, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 147Section 148Section 151

ACIT 2. The grievances of the assessee read as under: “1. On the facts and circumstances of the case and in law, the notice under section 148 of the Income Tax Act, 1961 issued in the case is bad-in-law, without jurisdiction and barred by limitation and, therefore

DCIT, CC-3, Ludhiana, Kitchlu Nagar vs. Mani Ram Balwant Rai HUF, Civil Lines

In the result, Cross Objection filed by the assessee is allowed and appeal of the Revenue is dismissed

ITA 1042/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh01 Sept 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 The Dcit, Mani Ram Balwant Rai, Huf, Central Circle-3, Vs Civil Lines, Opposite Session Court(Old) Kitchlu Nagar, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent & C.O. 43/Chd/2024 In आयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 Mani Ram Balwant Rai, Huf, The Dcit, Civil Lines, Opposite Session Court(Old) V Central Circle-3, Ludhiana. S Kitchlu Nagar, Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent Revenue By : Smt. Kusum Bansal, Cit Dr Assessee By : Shri Pankaj Bhalla, Ca & Shri Hunny Bajaj, Advocate Date Of Hearing : 17.07.2025 Date Of Pronouncement : 01.09.2025 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

For Appellant: Shri Pankaj Bhalla, CA and Shri Hunny Bajaj, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 132(1)Section 147Section 148Section 148ASection 151Section 151A

scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment or re- computation under section 147 or issuance of notice under section 148 81 [or conducting of enquiries or issuance of show-cause notice or passing of order under section 148A] or sanction for issue of such ... under : ITA No.1042/CHD/2024 & C.O. 43/CHD/2024 A.Y.2019-20 7 “6. We have duly considered the rival contentions and gone through the record carefully. Admittedly, notice under Section 148 was issued after the Notification issued by the Ministry of Finance, Government of India on 29.03.2022. The notice under Section 148 has been issued

Seenappa Chandra Shekar, Bengaluru vs. Income Tax Officer, Ward-4(2)(3), Bengaluru

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

ITA 22/BANG/2025[2016-17]Status: DisposedITAT Bangalore01 Sept 2025AY 2016-17

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

For Appellant: Shri Pranay Sharma, AdvocateFor Respondent: Shri Thamba Mahendra, Jt.CIT(DR)(ITAT), Bengaluru
Section 142Section 144Section 147Section 148

return was not picked up for scrutiny however later action under section 147 was initiated based on reasons recorded and notice under section 148 of the Act was served on 31/3/2021. The assessee was also issued notice under section 142 (1) and no compliance was made by the assessee ... sustainable. 11. Before the learned assessing officer, the assessee has not provided any information, assessee also even did not respond to the notices under section 148 of the Income Tax Act. The reason stated by the assessee that notice under section 148 of the Act was not found

M/S. Deepak Purshottam Shah (HUF), Mumbai vs. ACIT, Central Circle -2, Thane

In the result, both the appeals filed by the assessee are allowed

ITA 5593/MUM/2024[2013-14]Status: DisposedITAT Mumbai01 Sept 2025AY 2013-14

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 132Section 132ASection 139Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 153

Officer's jurisdiction to undertake proceedings has to be tested/examined only on the basis of reasons recorded at the time of issuing a notice under Section 148 of the Act seeking to reopen an assessment. These reasons cannot be improved upon and/or supplemented much less substituted by affidavit and/or oral

M/S. Deepak Purshottam Shah, Mumbai vs. ACIT, Central Circle -2, Thane

In the result, both the appeals filed by the assessee are allowed

ITA 5591/MUM/2024[2012-13]Status: DisposedITAT Mumbai01 Sept 2025AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 132Section 132ASection 139Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 153

Officer's jurisdiction to undertake proceedings has to be tested/examined only on the basis of reasons recorded at the time of issuing a notice under Section 148 of the Act seeking to reopen an assessment. These reasons cannot be improved upon and/or supplemented much less substituted by affidavit and/or oral

Sportking India Ltd., New Delhi vs. JCIT, Circle-9(1), New Delhi

The appeal of the assessee is allowed as above

ITA 2223/DEL/2018[2006-07]Status: DisposedITAT Delhi01 Sept 2025AY 2006-07

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 115JSection 143(3)Section 147Section 148Section 151Section 250

mandatory requirement of Section 151(2) has not been fulfilled. Section 151 requires a sanction to be taken for the issuance of a notice under Section 148 in certain cases. In the present case, an assessment had not been made under Section 143(3) or Section ... could have only been fulfilled by the satisfaction of the Joint Commissioner that this is a fit case for the issuance of a notice under Section 148. Section 151(2) mandates that the satisfaction has to be of the Joint Commissioner. That expression has a distinct meaning by virtue

Abdulkadar Hajiahmed Vadiwala, Jamnagar vs. Pr. Commissioner of Income Tax, Jamnagar

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

ITA 103/RJT/2025[2016-17]Status: DisposedITAT Rajkot29 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.103/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Abdulkadar Hajiahmed Vadiwala The Pr.Cit बनाम Maniar Street, Lindi Bazar Jamanagar. Jamnagar-361001 Vs. Pan : Aatpv 4729 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

For Appellant: Shri Chetan Agarwal, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 143(3)Section 147Section 148Section 151Section 263

year under consideration filed the return of income declaring a loss of Rs.3,37,77,313/-. The assessment was reopened by issue of notice under section 148 of the Act on 23.04.2021 and notice was deemed to be a notice issued under section 148A(b) as per the directions ... Supreme Court in the case Ashish Agrawal (supra). The AO issued a notice under section 148 dated 30.07.2022 after passing order under section 148A(d) of the Act. In the C.O. of AY 2016-17 one of the legal contentions raised by the assessee is that

Tulsi Jewellers, Na vs. Arivs.Income Tax Officer - Ward 5, Navsari

In the result assessee's appeal is allowed

ITA 947/SRT/2024[2017-18]Status: DisposedITAT Surat29 Aug 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.946 & 947/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Tulsi Jewellers Income Tax Officer, Ward-5, बनाम/ 7-8, Saibaba Complex Navsari, 204, 2Nd Floor, Income Vs. Gauaarbag, Nr Lmp School Tax Office, Charpool, Awabaug, Chikhli Roa Bilimora, Tal: Navsari-396 445 Gandevi-396 321 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakft 8368 G (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ashish Pophare, Cit-Dr & Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 29/08/2025

Section 115BSection 144Section 147Section 148Section 148ASection 250Section 271ASection 69A

148A(b) – to provide an opportunity of hearing to the assessee by serving upon them a show cause notice as to why a notice under section 148 should not be issued based on the information that suggests that income chargeable to tax has escaped assessment. It must be noticed that ... terms of Section 148-A(d) in respect of each of the assessee concerned.: Further, it directed the assessing officers to issue a notice under Section 148 of the new regime “after following the procedure as required under section 148-A.” Although this court waived off the requirement of obtaining

Tulsi Jewellers, Na vs. Arivs.Income Tax Officer, Ward 5, Navsari

In the result assessee's appeal is allowed

ITA 946/SRT/2024[2017-18]Status: DisposedITAT Surat29 Aug 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.946 & 947/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Tulsi Jewellers Income Tax Officer, Ward-5, बनाम/ 7-8, Saibaba Complex Navsari, 204, 2Nd Floor, Income Vs. Gauaarbag, Nr Lmp School Tax Office, Charpool, Awabaug, Chikhli Roa Bilimora, Tal: Navsari-396 445 Gandevi-396 321 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakft 8368 G (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ashish Pophare, Cit-Dr & Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 29/08/2025

Section 115BSection 144Section 147Section 148Section 148ASection 250Section 271ASection 69A

148A(b) – to provide an opportunity of hearing to the assessee by serving upon them a show cause notice as to why a notice under section 148 should not be issued based on the information that suggests that income chargeable to tax has escaped assessment. It must be noticed that ... terms of Section 148-A(d) in respect of each of the assessee concerned.: Further, it directed the assessing officers to issue a notice under Section 148 of the new regime “after following the procedure as required under section 148-A.” Although this court waived off the requirement of obtaining

Pakalapati Padma Jyothi, West Godavari Dist vs. Income Tax Officer, Ward-1, Tadepalligudem

In the result, appeal of the assessee is allowed

ITA 275/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam29 Aug 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.275/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Pakalapati Padma Jyothi V. Income Tax Officer – Ward – 1 D.No. 1-17, Singarajupalem Income Tax Office Muthyalamma Gudi Street Aayakar Bhawan Avapadu, Nellajerla D.No. 2-1-56/1, K.N. Road West Godavari District Tadepalligudem – 534101 Andhra Pradesh [Pan:Blwpp5193B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr.Ar

Section 142(1)Section 147Section 148Section 148ASection 151ASection 69A

cause notice under section 148A(b) of the Act with prior approval of competent authority requiring the assessee to show-cause why a notice under section 148 of the Act should not be issued on the basis of information. In response, assessee failed to respond to the notice. Thereafter ... issued notice under section 148 of the Act on 04.04.2022. Assessee filed return of income on 01.06.2022 and declared total income at Rs.3,05,670/-. Thereafter, notice under section 142(1) of the Act was issued requiring the assessee to submit certain details as called for. In response

Sudharani Surisetty, Visakhapatnam vs. Income-Tax Officer, Ward - 1(1), Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 166/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam29 Aug 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.166/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Sudharani Surisetty V. Income Tax Officer – Ward – 1 29-2-34, Opposite Judge Court Flat No. 401, 4Th Floor Main, Dabagardens Prathyakshar Bhawan Prakasharaopeta Mvp Double Road Visakhapatnam – 530020 Visakhapatnam – 530020 Andhra Pradesh Andhra Pradesh [Pan:Cnbps4046N] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Subrahmanyam, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparnavilluri, Sr.Ar

Section 142(1)Section 147Section 148Section 148ASection 149(1)(b)Section 250

that has escaped assessment representing in the form of Asset worth more than Rs. 5-50 lakhs has escaped assessment and therefore issued notice under section 148 of the Act on 06.04.2022. Assessee filed return of income on 08.04.2022 and declared total income at Rs.4,11,580/-. The return ... additional grounds since it goes to the root of the matter. 7. At the outset, Ld. Authorised Representative [hereinafter “Ld.AR”] submitted that notice under section 148 of the Act for the A.Y.2015-16 was issued on 06.04.2022 without following the procedure prescribed by the new provision inserted on 01.04.2021. Ld.AR also