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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

Deputy Commissioner of Income -Tax, Central Circle-1(2), Ahmedabad vs. Goyal and Co. (Const.) Private Limited., Ahmedabad

ITA 1836/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Aug 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1836/Ahd/2024 िनधा"रण वष" /Asst.Year 2016-17 The Dcit Goyal & Co. (Const.) Private बनाम/ Central Circle-1(2), Limited V/S. Ahmedabad – 380 009 10Th Floor Commerce House Iv Beside Reliance Petrol Pump 100Ft. Road, Satellite Ahmedabad – 380 015 अपीलाथ'/ (Appellant) !( यथ'/ (Respondent) .. & Cross Objection No.42/Ahd/2024 - िनधा"रण वष" /Ay 2016-17 (In Ita No.1836/Ahd/2024 – Ay 2016-17) V/S. Goyal & Co. (Const.) Private The Dcit Limited Central Circle-1(2), 10Th Floor,Commerce House Iv Ahmedabad – 380 009 Beside Reliance Petrol Pump 100Ft. Road, Satellite Ahmedabad – 380 015 Pan: Aabcg 5459 R (Cross Objector) .. (Respondent)

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Kavan Limbasiya, Sr.DR
Section 132Section 143(1)Section 143(3)Section 148Section 69

crore, which were not accounted for in the assessee’s books. 5.1. In light of this, the AO reopened the assessment by issuing notice under section 148, after recording reasons and obtaining sanction under section 151. 6. The AO rejected the assessee’s explanation that the ledger was a third

Anantha Pvc Pipes Private Limited, Anantapur vs. ACIT., Circle-1, Kurnool

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

ITA 317/HYD/2025[2017-18]Status: DisposedITAT Hyderabad06 Aug 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.317/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) M/S. Anantha Pvc Pipes Pvt. Ltd., Asst. Commissioner Of Income Tax, Vs. Circle-1, Kurnool. Anantapur. Pan:Aagca0936J (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri T. Rajendra Prasad, C.A. & Shri P. Rosi Reddy, Advocate. रधजस् व द्वधरध/Revenue By:: Dr. Sachin Kumar, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 31/07/2025 घोर्णध की तधरीख/Pronouncement: 06/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Anantha Pvc Pipes Pvt. Ltd. (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 25.07.2024 For The A.Y. 2017-18. 2. At The Outset, It Is Observed That There Is A Delay Of 147 Days In Filing The Present Appeal Before The Tribunal. In This Regard, The

For Appellant: Shri T. Rajendra Prasad, C.AFor Respondent: : Dr. Sachin Kumar, SR-DR

against further action in cases involving invalid returns. 4.1 Subsequently, reassessment proceedings were initiated under section 147 of the Act by issue of notice under section 148 of the Act dated 30.03.2021. In response, the assessee filed a return of income on 30.04.2021 declaring the same loss ... reopening.” Based on this, the Ld. AR argued that the reassessment proceedings were initiated without recording any reasons, and hence the issuance of notice under section 148 of the Act is void ab initio and the consequential reassessment order is liable to be quashed. 8. As regards the second issue

Kasireddy Sasikalamma, Nellore vs. ITO., Ward -1, Gudur

ITA 225/HYD/2025[2017-18]Status: DisposedITAT Hyderabad06 Aug 2025AY 2017-18

Bench: Us:

For Appellant: NoneFor Respondent: Shri Helen Ruby Jesindha
Section 147Section 148Section 68Section 69ASection 69BSection 69C

Sireesha Pochareddy, but had not filed her return of income, initiated proceedings under Section 147 of the Act. Notice under Section 148 of the Act dated 4 Kasireddy Sasikalamma 30.03.2021 was issued to the assessee. In compliance, the assessee filed her return of income on 19.04.2021 declaring an income

Asst.Commissioner of Income Taxcentral Circle-2(4), Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3885/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Aug 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3884/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Aug 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3883/MUM/2025[2021-22]Status: DisposedITAT Mumbai06 Aug 2025AY 2021-22

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3882/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Aug 2025AY 2023-24

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3881/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Aug 2025AY 2022-23

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Assistant Commissioner of Income Tax, Central Circle2, 4 Mumbai, Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3880/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Aug 2025AY 2020-21

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Asst.Commissioner of Income Taxcentral Circle-2(4), Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3879/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Aug 2025AY 2019-20

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Asst. Commissioner of Income Tax, Central Circle-2(4), Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, the captioned appeals by the revenue are partly allowed and cross-objections are allowed in part for statistical purposes

ITA 3863/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Aug 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri J D Mistri, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 131Section 133ASection 143(2)Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean withdrawal of claim ipso facto'. It was emphasised that

Harishchandra Laxman Dongre, Mumbai vs. Income Tax Officer Mum-W-(221)(1), Mumbai

In the result, the appeal filed by the assesse bearing ITA No

ITA 3582/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Aug 2025AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarharishchandra Laxman Income-Tax Officer, Mum-W- Dongre, 2(21)(1), Mumbai, 2Nd Floor, Pitru Chhaya, Kautilya Bhavan, Bkc, Mumbai-400 Govandi Station Road, 051 Sanghavi Estate, Mumbai-400 088 Pan : Anopd3687R Applicant Respondent

For Appellant: Shri Sanjiv G Brahme, CAFor Respondent: Shri Hemanshu Joshi, SR DR
Section 144Section 144BSection 147Section 148Section 249(2)Section 250

which tax of Rs.912/- was deducted at source. The assessee had not filed his return of income. Pursuant to issuance of notice under section 148 of the Act, the assessment was completed. While completing the assessment, the Ld. AO considered the assessee’s salary income at Rs.5,46,630/-, which

Mahesh Kumar, Delhi vs. ITO, Ward-68(6), Delhi

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2650/DEL/2024[2012-13]Status: DisposedITAT Delhi06 Aug 2025AY 2012-13

Bench: Justice (Retd.) C.V. Bhadang(), Shri Mahavir Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Mahesh Kumar, Vs Ito, 6/305/1A, Doonger Ward-68(6), Mohalla, Delhi-110032. Delhi. Pan-Aoopk6335A Appellant Respondent Appellant By Shri Neeraj Mangla, Ca Respondent By Shri Krishna K. Ramawat, Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 06.08.2025

Section 10(38)Section 143(3)Section 147Section 148Section 68

Another11 and where it was observed:- "8. Learned counsel for the assessee submitted that the Assessing Officer had reopened the assessment by issuing notice under section 148 of the Act on the ground that the income from salary, perquisites and unexplained cash deposits in various accounts along with interest thereon ... under Section 148A(d) dated 31.07.2022 [W.P.(C) 3807/2023], 23.07.2022 [W.P.(C) 3804/2023], and 29.07.2022 [W.P. (C) 3808/2023], respectively as well as the notices under Section 148 dated 31.07.2022 [W.P.(C) 3807/2023], 23.07.2022 [W.P.(C) 3804/2023], and 29.07.2022 [W.P.(C) 3808/2023], respectively are hereby quashed.” 11. Even Hon’ble High

Ultra Modern Exports Pvt. Ltd., New Delhi vs. ITO Ward - 27(1), New Delhi

ITA 527/DEL/2020[2011-12]Status: DisposedITAT Delhi06 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri M. Balaganesh

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 68

Unit 1(1), Mumbai vide letter dated 16-03-2018, the assessment of the assessee was sought to be reopened vide issuance of notice under section 148 of the Act. The said information informed that huge amount of bank transactions were carried out by Concise Exim Private Limited with many ... Addl. DIT (Inv.), Unit-1, Mumbai 7. Based on the aforesaid communication, the Learned AO recorded reasons for reopening the assessment and issued notice under Section 148 of the Act on 28-03-2018 to the Assessee Company after obtaining the prior approval of Learned Principal Commissioner of Income

Dhanji Murji Hirani, Kutch vs. ITO.(Int.Txn)Gandhidham, Gandhidham

In the result, the appeal of the assessee is allowed

ITA 131/RJT/2025[2019-20]Status: DisposedITAT Rajkot05 Aug 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.131/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2019-20 Dhanji Murji Hirani, Baladia Ito (Int.Txn), बनाम Bhuj, Kutch, Gandhidham Gujarat 370427 Vs. Pan : Afaph0463B (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr

For Appellant: Shri Kalpesh Doshi, ld.ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 115BSection 127Section 139Section 147Section 148Section 148ASection 234ASection 271ASection 69

signed by the concerned authority. We note that section 151 of the Act, mandates prior approval of the “specified authority” before issuing a notice under Section 148 for income escaping assessment. If the document granting approval lacks a manual or digital signature, it calls into question the authority's satisfaction ... received and the opportunity given, the order u/s 148A(d) AND/OR issuance said draft orders u/s 148A(d) of the IT Act of notice under section 148 of the are found in order. I am satisfied that this Income Tax Act, 1961? is fit case to issue notice u/s 148

Ankit Metal & Power Ltd., Kolkata vs. ACIT, Cen. Cir. 3(2), Kolkata

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

ITA 796/KOL/2024[2015-16]Status: DisposedITAT Kolkata05 Aug 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.796/Kol/2024 Assessment Year: 2015-16 Ankit Metal & Power Ltd………..……..…………………....Appellant 35, Chittaranjan Avenue, Kol-12. [Pan: Aaeca5230B] Vs. Acit, Central Circle-3(2), Kolkata…..…..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 22, 2025 Date Of Pronouncing The Order : August 05, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 09.01.2024 Passed By The Cit(A)-21, Kolkata [In Short Cit(A)] Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Was Subjected To Reassessment Proceedings Under Section 147 Of The Income-Tax Act, 1961 ("The Act") Pursuant To Information Gathered During Search & Seizure Operations Conducted Under Section 132 Of The Act In The Case Of One Sanjeev Kejriwal & His Group Entities. During The Course Of Such Proceedings, It Was Revealed That Mr. Kejriwal Was Engaged In Providing Accommodation Entries Through Various Concerns Including: M/S Rajputana General Commercial Corporation Pvt. Ltd., M/S Arvind Trading Company & M/S Shri Krishna Trading Company. In His Sworn Statement, Mr. Kejriwal Admitted That These Entities Were Non-

Section 132Section 143(3)Section 147Section 148Section 250Section 68

entities like M/s Rani Sati Metal Industries, M/S Rani Sati Industries Ltd., and M/S TIF Casting Ltd. amounting to Rs.1,10,00,000/- notice under section 148 was issued to the assessee. Subsequently, notices under sections 143(2) and 142(1) were issued, seeking explanation and supporting evidence regarding

Gupta Builders and Developers, Mumbai vs. ACIT Central Circle 4(3), Mumbai

In the result, ground no

ITA 69/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Aug 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosainassessment Year : 2016-17 Gupta Builders & Developers, Asst. Commissioner Of 1201 & 1202, Income Tax, Bhumiraj Costarica, Vs. Central Circle-4(3), Plot No.1 & 2, Room No. 1921, 19Th Floor, Near Moraj Circle, Air India Building, Sector-18, Sanpada, Nariman Point, Navi Mumbai-400705. Mumbai-400021. Pan :Aajfg3066H (Appellant) (Respondent) Assessee By : Ms. Ritika Agarwal Revenue By : Shri Swapnil Choudhary

For Appellant: Ms. Ritika AgarwalFor Respondent: Shri Swapnil Choudhary
Section 147Section 148Section 148A

148A(d) in respect of each of the concerned assessees; Thereafter after 4 following the procedure as required under section 148A may issue notice under section 148 (as substituted); (iv) All defences which may be available to the assesses including those available under section

Mr. Rohit Ramesh Kapoor, Mumbai vs. ITO Ward 42(3)(2), Mumbai

In the result, grounds of appeal raised by assessee are partly allowed

ITA 2416/MUM/2025[2015-16]Status: DisposedITAT Mumbai05 Aug 2025AY 2015-16

Bench: Shri Pawan Singh, Hon’Bleand Shri Omkareshwar Chidaramr. Rohit Ramesh Kapoor Ito, Ward-42(3)(2) Mumbai S/O. Ramesh Chandra Kapoor, 301, Room No. 609, Kautilya Bhawan 3Rd Floor, Exotica Apartment, Plot Vs C-41 To C-43, G Block, Bkc No. 91, Sector 12, Vashi, Bandra (E), Mumbai – 400051. Navi Mumbai-400703. Pan: Avdpk8131E (Appellant) (Respondent ) Assessee Represented By : Shri V.D. Parmar, Advocate Shri Annavaran Kasuri, Sr. Dr Department Represented By : 07.04.2025 Date Of Institution : Date Of Conclusion Of Hearing : 05.08.2025 Date Of Pronouncement Of Order : 05.08.2025

Section 144Section 147Section 148Section 148ASection 254(1)

file of assessing officer for de novo assessment. The ld. AR submits that he has a very limited prayer about issuance of notice under section 148 by jurisdiction assessing officer when assessment was completed in a faceless manner. At the time of hearing, the ld. AR of the assessee ... appraised about the fact that issue relating to issuance of notice under section 148 by jurisdictional assessing officer (JAO) vis-à-vis by faceless assessing officer (FAO) is now pending before Hon’ble Supreme Court. Thus, it would not be appropriate by this bench to give any decision on such

Amjad Usman Khan, Thane vs. DCIT, Circle 1, Thane

In the result, the appeal by the assessee is dismissed

ITA 1973/MUM/2025[2013-14]Status: DisposedITAT Mumbai05 Aug 2025AY 2013-14

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year 2013-14

For Appellant: NoneFor Respondent: Shri Aditya M. Rai, Sr.DR
Section 142(1)Section 143(3)Section 144Section 147Section 148Section 250Section 50CSection 54

amount of Rs.3.35 crore which attracts the provisions of section 50C of the Act for computing the capital gains, notice under section 148 of the Act was issued on 31.03.2021 and proceedings under section 147 of the Act were initiated. In response to the aforesaid notice, the assessee submitted that

Ketan J Shah (Partner of Ketval Gems), Mumbai vs. Income Tax Officer Ward 21(2)(1), Mumbai

In the result, ground no. 1 of the

ITA 4212/MUM/2024[2014-15]Status: DisposedITAT Mumbai05 Aug 2025AY 2014-15

Bench: Shri Pawan Singh(Physical Hearing) Ketan J Shah (Partner Of Ketval Gems) Ito, Ward – 21(2)(1), Mumbai 5/67, Adarsh Nagar, Opp. Century Vs 110, Piramal Chambers, Lalbaug, Bazar, Mumbai – 400025. Parel, Mumbai - 400012. [Pan: Aaafk1724D] Appellant / Assessee Respondent / Revenue

Section 143(3)Section 147Section 148Section 153Section 254(1)

purchases as well as time period for passing assessment order under section 153 and validity of reopening under section 147 and issuance of notice under section 148. However, at the time of making submission, the learned authorised representative (ld AR) of the assessee has not made any submission either against ... time period for passing assessment order under section 153 or against the validity of reopening under section 147 or issuance of notice under section 148. Therefore, such grounds of appeal are treated as not pressed and dismissed. Ground no. 1 relates to restricting the addition to the extent