“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

Rajesh Baburao Shinde, Parbhani vs. ITO, Ward- Hingoli, Hingoli

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

ITA 781/PUN/2025[2015-16]Status: DisposedITAT Pune12 Aug 2025AY 2015-16

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.781/Pun/2025 िनधा"रण वष" / Assessment Year : 2015-16 Rajesh Baburao Shinde, Vs. Assessment Unit, Income Sayala Khating, Tq. Dist. Tax Department, Nfac, Parbhani- 431402. Delhi. Pan : Czcps6546Q Appellant Respondent Assessee By : Shri Shubham N. Rathi Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 22.07.2025 Date Of Pronouncement 12.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2015-16. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Akhilesh Srivastva

Section 142(1)Section 145Section 148Section 148ASection 151ASection 69A

Hingoli ['the Ld. JAO'] has erred in initiating the reassessment proceedings u/s 145 of the Income tax Act, 1961 ["the Act'] without serving notice under section 148 of the Income-tax Act, 1961. 1.2 On the facts and in the circumstances of the case, the Ld. JAO has initiated

Income Tax Officer, Piramal Chambers Mumbai vs. Bharat Hiralal Shah, Mumbai

In the result, the appeal of the Revenue is allowed for eal of the Revenue is allowed for statistical purposes

ITA 729/MUM/2025[2010]Status: DisposedITAT Mumbai12 Aug 2025

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2010-11 Ito, Bharat Hiralal Shah, 501 5Th Floor, Income Tax Office 220, 4Th Floor Badrikashram 1St Piramal Chambers Lalbaug, Vs. Khetwadi Lane, Mumbai-400012. Mumbai-400004. Pan No. Aaeps 5511 N Appellant Respondent

For Appellant: Ms. Khushali PandyaFor Respondent: Mr. Pravin Salunkhe, Sr. DR

material submitted by the assessee in response to detailed scrutiny of the material submitted by the assessee in response to the notice under Section 148 Section 148 issued by the AO, as also the material issued by the AO, as also the material submitted at the stage of appeals

Income Tax Officer, Mumbai vs. Tejas Bharatkumar Saglani, Mumbai

In the result, grounds No

ITA 4312/MUM/2025[2011]Status: DisposedITAT Mumbai12 Aug 2025

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2011-12 Ito, Tejas Bharatkumar Saglani, 4Th Floor, Room No. 405, Piramal Shop No. 22/23, Santoshi Mata Chambers, Lal Baug, Parel, Vs. Chs, Below Reliance Super, Mumbai-400012. Lamington Road, Mumbai-400008. Pan No. Azjps 8276 Q Appellant Respondent

For Respondent: Mr. Rasik Tanna

material submitted by the assessee in response to detailed scrutiny of the m aterial submitted by the assessee in response to the notice under Section 148 Section 148 issued by the AO, as also the material issued by the AO, as also the material submitted at the stage of appeals

ITO-23.1.6, Mumbai vs. Ghevarchand Jethmalji Jain, Mumbai

ITA 3859/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Aug 2025AY 2015-16

Bench: Justice (Retd.) C.V. Bhadang & Ms. Padmavathy S.: A.Y. : 2015-16 Ito-23(1)(6), Vs. Ghevarchand Jethmalji Jain 704, 7Th Floor, Safalya Bldg., Tarabag, Mumbai. (Appellant) Love Lane Mazgaon, Mumbai 400 010. Pan : Aadpj2435M (Respondent)

For Appellant: Shri Swapnil ChoudharyFor Respondent: Shri Harsh Kapadia &

Section 147Section 148Section 148ASection 149Section 253ASection 68

processed and an intimation was issued on 19.09.2015. Subsequently, the AO sought 2 Ghevarchand Jethmalji Jain to reopen the assessment by issuance of notice under Section 148 of the Act on 28.06.2021, which was followed by a show cause notice under Section 148A(b) of the Act dated 24.05.2022. Finally ... dated. 17.09.2024.” 6. It is submitted by the learned DR that the CIT(A) was not justified in quashing the reopening as the notice under Section 148 of the Act was issued within the limitation provided under Section 149 of the Act and the proviso thereto in pursuance

Tata Motors Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

ITA 3511/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Aug 2025AY 2014-15

Bench: Shri Amit Shukla, Hon'Ble & Shri Arun Khodpia, Hon'Ble

Section 115BSection 115JSection 143(2)Section 143(3)Section 147Section 148Section 154Section 250Section 32A

aforesaid decisions lay down to the facts of the present case, we may observe that the Assessing Officer in issuing the impugned notice under Section 148 of the IT At has clearly acted without jurisdiction. This firstly for the reason that the Assessing Officer was reopening an assessment beyond

Dy. Commissioner of Income Tax, Ghaziabad vs. Ritu Cansal, Ghaziabad

ITA 2113/DEL/2024[2017]Status: DisposedITAT Delhi12 Aug 2025

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 147Section 148Section 148ASection 151Section 151(1)Section 151(2)

assessments. The provision imposes a responsibility on the Revenue to ensure that it obtains the sanction of the specified authority before issuing a notice under Section 148. The purpose behind this procedural check is to save the assesses from harassment resulting from the mechanical reopening of assessments. 128 A table ... year. Thus, non- compliance by the assessing officer with the strict time limits prescribed under Section 151 affects their jurisdiction to issue a notice under Section 148. 77. Parliament enacted TOLA to ensure that the interests of the Revenue are not defeated because the assessing officer could not comply with

M/S. India Exposition Mart Ltd., New Delhi vs. DCIT, New Delhi

Appeal of the Assessee stands allowed

ITA 1079/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Aug 2025AY 2009-10

Bench: Shri Mahavir Singhshri Kuldip Singh & Shri Anadee Nath Misshra, Accountnat Member Shri Vikas Awasthy & Shri Brajesh Kumar Singh

For Appellant: Shri A. K. Khanna, C. A./NoneFor Respondent: Shri M.S. Nethrapal, CIT-DR

Section 139(1)Section 147Section 148

extremely unable to uphold the contention raised on behalf of the petitioner that the respondent authority has no jurisdiction to issue the impugned notice under section 148 of the Income-tax Act, 1961 as it involved only a mere change of opinion.” This court in Praful Chunilal Patel ... with Statement of Facts and Ground of Appeal filled with CIT (A) Copy of Representation before CIT(A)-4 dated 29/10/15 Copy of Notice under section 148 Dated 11/03/2013 issued by DCIT Cir 11(1) Letter dated 19.03.2014 by the assessee to DCIT Circle 11(1) asking the reason

Rajulhoubienuo Angami, Nagaland vs. ITO Ward 2, Dimapur

Appeal of the assessee is partly allowed for statistical purposes

ITA 26/GTY/2025[2015-16]Status: DisposedITAT Guwahati11 Aug 2025AY 2015-16

Bench: This Hon'Ble Tribunal Assailing The Order Dated 24.06.2024 Passed By The Learned Commissioner Of Income Tax (Appeals) ["Ld. Cit(A)"]. That The Due Date For Filing The Appeal Was 24Th August, 2024. However, There Has Been An Unintentional Delay Of 166 Days (Upto 13Th February, 2025), In Filing The Present Appeal, For Which The Appellant, With Utmost Humility, Seeks The Indulgence Of This Hon'Ble Tribunal For Condonation Of The Said Delay On The Grounds Set Forth Herein. 2. It Is Submitted That The Mr. Shivendu Maharaj Is The Accountant Of The Appellant Who Looks After The Tax Portal & Email Updates. The Accountant Also Forwards The Needful To The Chartered Accountant, Mr. Ajit Jain, To Take Necessary Action In Response To Any Notice That Is Received.

Section 10(26)Section 147Section 250Section 69A

sharing of "reason to believe" make the entire reassessment proceedings negatory and without jurisdiction. Therefore, the impugned reopening notice under section 148 I.T.A. No. 26/GTY/2025 Rajulhoubienuo Angami as well as the consequential proceedings under section 147 of the Act must be quashed. 5. That in the facts and circumstances ... order was bad in law since no notice under Section 143(2) of the Act was given even though in response to notice under Section 148 of the Act an ITR was filed on 19.01.2022. The Ld. AR drew our attention to the relevant recording of fact

Sh. Kapil Taneja, Jaipur vs. The Deputy Commissioner of Income Tax Circle-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 578/JPR/2025[2017-18]Status: DisposedITAT Jaipur11 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Gorav Avasthi, JCIT

Section 144BSection 147Section 148Section 148ASection 151ASection 69A

with TOLA will be available to the Revenue to complete the remaining proceedings in furtherance of the deemed notices, including issuance of reassessment notices under section 148 of the new regime. The surviving or 11 Sh. Kapil Taneja vs. DCIT balance time limit can be calculated by computing the number ... take a decision under section 149A(d) based on the available material and the reply of the assessee; and (iii) issue a notice under section 148 if it was a fit case for reassessment. Once the clock started ticking, the assessing officer was required to complete these procedures within

DCIT, Circle-I, Ludhiana vs. Hemant Sood (HUF), Ludhiana

In the result, Revenue’s appeal is partly allowed

ITA 890/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Aug 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 890/Chd/2024 "नधा"रण वष" / Assessment Year : 2015-16 Deputy Commissioner Of M/S Hemant Sood Income Tax, Circle-1, बनाम (Huf), Ludhiana. H.No 417-2, Sohi Vs. Street, College Road, Ludhiana. "थायी लेखा सं./Pan No: Aadhh2051P अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By: Sh. Ashwani Kumar, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 24.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 24-06-2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

For Appellant: Sh. Ashwani Kumar, CAFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR

Section 10(38)Section 143(3)Section 147Section 148

passed the assessment order under Section 147 read with Section 143(3). In other words, assessment was reopened by issuance of a notice under Section 148. This re-opening has not been upheld by the ld. CIT(A). The re-opening has been declared as bad in the eyes

Jayshree Nilam Patel, Ahmedabad vs. The ITO, Ward-1, Intl. Taxn., Ahmedabad

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

ITA 942/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad11 Aug 2025AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul Thakkar, ARFor Respondent: Smt. Malarkodi R., Sr. DR

Section 132Section 142(1)Section 143(2)Section 144Section 147Section 148Section 148ASection 271A(1)(d)Section 272(1)(d)Section 272A(1)(d)

under clause (b) of section 148A of the Act was issued. The order under section 148A(d) was passed on 04.07.2022, and a notice under section 148 of the Act was issued directing the assessee to file her return of income. Thereafter, multiple notices under section

Shaival Comcon LLP, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 549/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad11 Aug 2025AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Jignesh Parikh, ARFor Respondent: Ms. Malarkodi R., Sr. DR

Section 115BSection 144Section 147Section 148Section 69

443/1, Mithakali, Ahmedabad. In view of the assessee’s failure to file the return voluntarily, the Assessing Officer issued a notice under Section 148 of the Income-tax Act, 1961 (Act) on 30.03.2021 to initiate reassessment proceedings. As there was no response to various notices issued by the Assessing Officer

Vinod Kumar Giri, Howrah vs. ITO, Ward 47(1), Kolkata

In the result, the appeal stands dismissed and the substantial question of law is answered against the revenue

ITA 716/KOL/2025[2018-19]Status: DisposedITAT Kolkata11 Aug 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No. 716/Kol/2025 Assessment Year: 2018-2019 Vinod Kumar Giri,…………………….…………..Appellant 158/2/1, Belilious Road, Kadamtala, Howrah-711101, West Bengal [Pan:Adxpg2995E] -Vs.- Income Tax Officer,…………………………......Respondent Ward-47(1), Kolkata, 3, Government Place (West), Kolkata-700001 Appearances By: Shri Vikash Surana, A.R., Appeared On Behalf Of The Assessee Shri S.B. Chakraborthy, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 30, 2025 Date Of Pronouncing The Order: August 11, 2025 O R D E R

Section 119Section 147Section 148Section 148ASection 68

Income Tax Act and asked response from the assessee. In absence of reply from the assessee, the case was reopened. A notice under section 148 of the Income Tax Act was issued and in response to the same, the assessee filed income tax return disclosing total income at Rs.30 ... Vinod Kumar Giri law for the reason that the ld. Assessing Officer having no jurisdiction over the assessee, in fact, not issued notice under section 148 of the Act. The ld. A.R. further challenges that as per the CBDT Instruction, monetary limits for assigning cases being non-corporate assessee, have

ITO, Ward-6(2), Kolkata vs. Raghuvir Retailers Pvt. Ltd., Kolkata

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

ITA 1129/KOL/2025[2012-13]Status: DisposedITAT Kolkata11 Aug 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No. 1129/Kol/2025 Assessment Year: 2012-2013 Income Tax Officer,………………..……………..Appellant Ward-6(2), Kolkata, Aayakar Bhawan, 6Th Floor, P-7, Chowringhee Square, Kolkata-700069 -Vs.- Raghuvir Retailers Pvt. Limited,.……….....Respondent Mandawa Shikhar, 151, Sarat Bose Road, Kolkata-700026 [Pan:Aaecr8231M] Appearances By: Shri S.B. Chakraborthy, Sr. D.R., Appeared On Behalf Of The Revenue Shri Abhisek Bansal, A.R., Appeared On Behalf Of The Assessee

Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 68

declaring total income at NIL. It appears that during the assessment year 2012- 13, the assessee-Company has escaped assessment. Accordingly, a notice under section 148 of the Act was issued and in response to the same, the assessee filed its return of income declaring total income ... first issue is concerned the answer has to be in the negative. Since the petitioners were called upon to file objection to the notice under section 148 proposing to reopen the assessment on the ground a sum of Rs.73,219 had "escaped income", the respondents cannot shift their stand

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 959/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Aug 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunatha

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT

Section 147Section 148Section 263Section 263(1)(i)

Assessing Officer. The only requirement is that the Assessing Officer ought to have considered the objection now raised in the grounds for issuing notice under Section 148 of the Act, during the original assessment proceedings. There can be no doubt in the present facts as evidenced by a letter dated

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 958/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Aug 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 951 To 953/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2013-14, 2014-15 & 2015-16 Subramaniam Mohan Sundaram, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aerpm-3937-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 954 & 955/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2017-18 & 2018-19 Subramaniam Mohan Sundaram Pcit (Central)-2, Legal Heir Of Late Smt. K.Lakshmi, Vs. Chennai. 395, Oppanakara Street Coimbatore – 641 001. [Pan: Aazpl-6816-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.: 956 To 959/Chny/2025 ननर्ाारण वर्ा / Assessment Years: 2015-16, 2016-17, 2018-19 & 2020-21 Mohansundaram Jayasuja, Pcit (Central)-2, 395, Oppanakara Street Vs. Chennai. Coimbatore – 641 001. [Pan: Aiypj-4331-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent)

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT

Section 147Section 148Section 263Section 263(1)(i)

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 957/CHNY/2025[2016-17]Status: DisposedITAT Chennai11 Aug 2025AY 2016-17

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT

Section 147Section 148Section 263Section 263(1)(i)

Mohansundaram Jayasuja, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 956/CHNY/2025[2015-16]Status: DisposedITAT Chennai11 Aug 2025AY 2015-16

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT

Section 147Section 148Section 263Section 263(1)(i)

Subramaniam Mohan Sundaram, Coimbatore vs. PCIT, Central, Chennai

ITA 955/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Aug 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 951 To 953/Chny/2025 निर्धारण वर्ष / Assessment Years: 2013-14, 2014-15 & 2015-16 Subramaniam Mohan Sundaram, 395, Oppanakara Street Vs. Pcit (Central)-2, Chennai. Coimbatore – 641 001. [Pan: Aerpm-3937-R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.: 954 & 955/Chny/2025 निर्धारण वर्ष / Assessment Years: 2017-18 & 2018-19 Subramaniam Mohan Sundaram Legal Heir Of Late Smt. K.Lakshmi, Vs. Pcit (Central)-2, Chennai. 395, Oppanakara Street Coimbatore – 641 001. [Pan: Aazpl-6816-A] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.: 956 To 959/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17, 2018-19 & 2020-21 Mohansundaram Jayasuja, 395, Oppanakara Street Coimbatore - 641 001. [Pan: Aiypj-4331-M] (अपीलार्थी/Appellant) Pcit (Central)-2, Vs. Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. S. Sundararaman, C.A (Erode) & Shri. S.Anatharaman, Advocate. प्रत्यर्थी की ओर से/Respondent By : Shri. Bipin C.N, Cit. सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोषणा की तारीख/Date Of Pronouncement : 11.08.2025 :-2-:

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT

Section 147Section 148Section 263Section 263(1)(i)

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL, 'C' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Subramaniam Mohan Sudaram, Coimbatore vs. PCIT, Central, Chennai

In the result both the appeals of the assessee for the assessment years 2017-

ITA 954/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Aug 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunatha

For Appellant: Shri. S. Sundararaman, C.A (Erode) &For Respondent: Shri. Bipin C.N, CIT

Section 147Section 148Section 263Section 263(1)(i)