“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

Ashok Dhanraj Chordia, Pune vs. PCIT, Pune-1, Pune

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

ITA 977/PUN/2024[2017-18]Status: DisposedITAT Pune30 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR

Section 132Section 143(1)Section 143(2)Section 147Section 148Section 263

abovementioned order and the case records, the following facts are observed : 2.1 The Proceedings under section 147 of the Act were initiated vide notice under section 148 of the Act dated 31/03/2021 in your case for A.Y. 2017-18 based on information and documents received by the Assessing Officer from ... your name under the code name of ‘ADC’ of ‘1500/’ and ‘Ashok C’ of ‘500’. Whereas while disposing your objection to the said notice under section 148 of the Act, the Assessing Officer vide para 6 of the order dated 13/12/2021 has held that “there are no entry

Kurri Narasimha Rao, Hyderabad vs. Income Tax Officer, Ward-1, Kothagudem

ITA 131/HYD/2025[2013-14]Status: DisposedITAT Hyderabad30 Jul 2025AY 2013-14

Bench: Us:

Section 147Section 148Section 44ASection 69

bank account, but had not filed his return of income for the year in question, initiated proceedings under Section 147 of the Act. Notice under Section 148 of the Act, dated 31.03.2021, was issued to the assessee. In compliance, the assessee filed his return of income, declaring an income ... jurisdiction that was assumed by the A.O. for framing the assessment on the ground that the A.O. had failed to issue any notice under Section 148 of the Act. However, the CIT(A) did not find favour with the aforesaid claim of the assessee and dismissed the said contention

Bhumika Patel, Kolkata vs. ITO Ward 29(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1150/KOL/2025[2010-11]Status: DisposedITAT Kolkata30 Jul 2025AY 2010-11

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1150/Kol/2025 Assessment Year: 2010-11 Bhumika Patel……………..……...……..…………………....Appellant 6, Burdwan Road, Block A Flat No.-4A/B, Konark Garden, Kol-27. [Pan: Alnpp8896P] Vs. Ito, Ward-29(1), Kolkata…………………..………………….…..... Respondent Appearances By: Shri Akshay Rinsia, Ar & T N Jaiswal, Ar, Appeared On Behalf Of The Appellant. Shri Kallol Mistry, Jcit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 29, 2025 Date Of Pronouncing The Order : July 30, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 17.03.2025 Passed By The Nfac [In Short Cit(A)] Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Are That The Case Of The Assessee Was Reopened Under Section 147 Of The Income-Tax Act, 1961, On The Basis Of Information Received From The Adit (Investigation), Rajkot. It Was Reported That M/S. Bhoomidev Credit Corporation Ltd. Was Engaged In Providing Accommodation Entries & The Assessee Was Identified As One Of The Beneficiaries. As Per The Investigation Findings That, A Cash Amount Of ₹75 Lakhs Was Deposited In The Books Of M/S. Bhoomidev Credit Corporation Ltd. & An Amount Of ₹66,14,712 Appeared As An Outstanding Loan In Its Balance Sheet In The Name Of The Assessee. Based On This Information, The Ao Recorded Reasons To Believe That

Section 147Section 148Section 250Section 68

recorded reasons to believe that I.T.A. No.1150/Kol/2025 Bhumika Patel income chargeable to tax had escaped assessment and, after obtaining due approval, issued notice under Section 148. Subsequent notices under Sections 143(2) and 142(1) were also issued. In response, the assessee submitted computation of income, profit and loss account

Rinku Rani Panja, Paschim Midnapore vs. I.T.O., Ward - 1(3), Midnapore, Paschim Medinipur

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

ITA 1471/KOL/2024[2011-2012]Status: DisposedITAT Kolkata30 Jul 2025AY 2011-2012

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1471/Kol/2024 Assessment Year: 2011-2012 Rinku Rani Panja,………..………………..………Appellant D-28, Burdge Town, Kotwali, Midnapore-721101, West Bengal [Pan:Anipp7116R] -Vs.- Income Tax Officer,……………………………..Respondent Ward-1(3), Midnapore, Office Of The Addl./Jt. Commissioner Of Income Tax, Amaravati Building, 1St Floor, Keranitola, Midnaporle-721101, West Bengal Appearances By: N O N E, Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 24, 2025 Date Of Pronouncing The Order: July 30, 2025 O R D E R

Section 142(1)Section 143(2)Section 147Section 148

case was selected for scrutiny under section 147 of the Act. For the initiation of scrutiny proceedings, statutory notice under section 148 of the Act was issued on 30.11.2012, 2 Rinku Rani Panja which was duly served upon the assessee. Statutory notice under section 143(2) of the Act dated

Income Tax Officer, Exemptions Ward, Trichy vs. Arulmigu Swaminatha Swami Thirukkovil, Kumbakonam

In the result, the appeals filed by the revenue in ITA Nos

ITA 370/CHNY/2025[2013]Status: DisposedITAT Chennai30 Jul 2025

Bench: Shri S.S.Viswanethra Ravi & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 370 & 368/Chny/2025 & Co Nos.32 & 33/Chny/2025 (In Ita Nos.: 370 & 368/Chny/2025) धनिाारण वर्ा / Assessment Year: 2013-14 & 2014-15 Income Tax Officer, Arulmigu Swaminatha Swami Exemptions Ward, Trichy, Thirukkovil, Vs. The Executive Officer, Swamimalai, Kumbakonam – 612 301. [Pan: Aaata-6446-J] (अपीलाथी/Appellant) (Respondent/Cross Objector) अपीलाथीकीओरसे/ Appellant By : Shri. P. Krishna Kumar, J.C.I.T. प्रत्यथीकीओरसे/Respondent By : Shri. N. Arjun Raj, Advocate सुनवाई की तारीख/Date Of Hearing : 09.05.2025 घोर्णा की तारीख/Date Of Pronouncement : 30.07.2025 आदेश /O R D E R Per Bench: These Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Years 2013-14 & 2014-15, Vide Order Dated 20.12.2024. Since The Facts Are Identical & Issues Are Common, Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Were Heard & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri. P. Krishna Kumar, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 10Section 11Section 12A(1)(b)Section 139Section 139(1)Section 147

reckoned as nullity in law for want of jurisdiction and further ought to have appreciated that having served upon the appellant the notice under Section 148 of the Act on 05.04.2021, the non-adherence to the procedure laid down in Section 148A of the Act, with effect from

The Income Tax Officer, Exemptions Ward, Trichy vs. Arulmigu Swaminatha Swami Thirukkovil, Kumbakonam

In the result, the appeals filed by the revenue in ITA Nos

ITA 368/CHNY/2025[2014-15]Status: DisposedITAT Chennai30 Jul 2025AY 2014-15

For Appellant: Shri. P. Krishna Kumar, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 10Section 11Section 12A(1)(b)Section 139Section 139(1)Section 147

Krishnavel Umamaheswari, Madurai vs. ACIT, Ncc-1, Madurai

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

ITA 1299/CHNY/2025[2013-14]Status: DisposedITAT Chennai30 Jul 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1299/Chny/2025 िनधा"रण वष"/Assessment Year: 2013-14 Krishnavel Umamaheswari, Vs. The Assistant Commissioner Of 10E, Nallamadan Koil Lane, Income Tax, North Masi Street, Madurai 625 001. Non Corporate Circle 1, Madurai. [Pan:Aaopu8528K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 30.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2013-14. 2. The Assessee Raised 2 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A)

For Appellant: NoneFor Respondent: Ms. V. Supraja, Addl.CIT

Section 139Section 143(2)Section 147Section 148Section 194DSection 194H

filed income tax return under section 139 of the Income Tax Act, 1961 [“Act” in short]. Accordingly, the Assessing Officer issued notice under section 148 of the Act. In response to the above notice, the assessee filed income tax return on 29.04.2021 declaring total income of ₹.14,46,980/-. Against

Narayana Rao Sujatha, Chamarajanagar vs. Income Tax Officer, Ward-1, Chamarajanagar

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

ITA 803/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Jul 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri R Chandrashekar, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate for Standing

Section 143(2)Section 148Section 234Section 250Section 69A

natural justice and equity on the facts and circumstances of the case 4. The learned assessing officer was not justified in issuing a notice under section 148 of the Act, when the time limit to issue notice under section 143(2) of the Act has not lapsed for the relevant

Anil Ramniranjan Kejriwal, Mumbai vs. Circle 24(1), Mumbai

In the result appeals filed by the assesse for assessment years 2013-14 to 2015-16 stands allowed

ITA 3336/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara()

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 151Section 68

same, the assessee filed his return of income. The Ld.AO issued order under section 148A(d) rejecting assessee’s objections Thereafter notice under section 148 was issued on 25/03/2022. 2.3 During the course of assessment proceedings, the Ld.AO issued notice u/s142(1) & show-case notice. In response to the same ... that the power to reopen should be exercised with due care and without any prejudice. 4.2 In our opinion, the assessing officer issued notice under section 148 of the act without application of mind as the assessment records had all relevant details to come to the conclusion either income chargeable

Anil Ramniranjan Kejriwal, Mumbai vs. Circle 24(1), Mumbai

In the result appeals filed by the assesse for assessment years 2013-14 to 2015-16 stands allowed

ITA 3335/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara()

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 151Section 68

Anil Ramniranjan Kejariwal, Mumbai vs. Circle 24(1), Mumbai

In the result appeals filed by the assesse for assessment years 2013-14 to 2015-16 stands allowed

ITA 3334/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2025AY 2013-14

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara()

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 151Section 68

Income Tax Officer-12(3)(1), Mumbai vs. Manju Diamonds Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of statistical purposes whereas the application under Rule 27

ITA 2766/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jul 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2017-18 Ito-12(3)(1), Manju Diamonds Pvt. Ltd., R.No. 145, 1St Floor, Aayakar 57/59, 1St Floor, Nagdevi Street, Vs. Bhavan, M.K. Road, Maszid Bunder, Mumbai-400020. Mumbai-400 003. Pan No. Aaecm 6609 G Appellant Respondent

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Ms. Dinkle Hariya

Section 133(6)Section 68

assessment within the meaning of Section 147 of the Act. escaped assessment within the meaning of Section 147 of the Act. Accordingly, a notice under Section 148 of the Act was issued on a notice under Section 148 of the Act was issued on a notice under Section 148

Maharashtriya Aikyavardhak Paraspar Sahakari Mandal Patpedhi Ltd., Mumbai vs. Income Tax Officer, Ward 14(2)(1), Mumbai

In the result, the appeal of the assess

ITA 1668/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jul 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19 Maharashtriya Aikyavardhak Ito Ward 14(2)(1), Paraspar Sahakari Mandal Room No. 457, Aayakar Bhavan, Vs. Patpedhi Ltd., M.K. Road, New Marine Lines, A Wing, 1St Floor, Pranay Mumbai-400020. Sudarshan, Joshi Lane, Ghatkopar East, Mumbai-400077. Pan No. Aabam 5906 H Appellant Respondent

For Appellant: Mr. Kumar Kale, AdvFor Respondent: Mr. Pravin Salunkhe, Sr. DR

Section 249(2)Section 80P

31st May 2021, whichever is later; (c) Income-tax return in response to notice under section tax return in response to notice under section 148 of the Income 148 of the Income-tax Act, 1961, for which the last date of filing of return of income under the said

Aseem Sehgal, Delhi vs. ITO, Ward-60(1), Delhi

ITA 156/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 147Section 148Section 148A

Learned AO under section 147 of the Act on the basis of information received from DCIT, Central Circle-26 and accordingly a notice under section 148 of the Act dated 31-3-2021 has been issued to the assessee on 1-4-2021 vide email ... evidence of notice under section 148 of the Act being issued to the assessee by email is enclosed in page 5 of the paper book. The notice issued by the Learned AO under section 148 of the Act dated 31-3-2021 issued to the assessee

Aseem Sehgal, Delhi vs. ITO, Ward-60(1), Delhi

ITA 155/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Jul 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Ayush Garg, CA

Section 147Section 148Section 148A

Aseem Sehgal, Delhi vs. ITO, Ward-60(1), Delhi

ITA 154/DEL/2025[2015-16]Status: DisposedITAT Delhi30 Jul 2025AY 2015-16

Bench: Shri M. Balaganesh & Shri Sudhir Kumar

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 147Section 148Section 148A

Jai Shree Balaji Builders Private Limited, Delhi vs. Income Tax Officer, Ward 13(1), Delhi

Appeal are disposed off

ITA 6062/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Jul 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Avdhesh Kumar Mishrajai Shree Balaji Builders Vs. Income Tax Officer, Private Limited Ward 13(1) Gali No. 5, 05/138A C.R. Building Shakti Vihar, Delhi – 110002 New Delhi – 110044 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccj5201F Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Om Prakash, Sr. DR

Section 144Section 147Section 148Section 251Section 94CSection 94H

this that the proceeding under Section 147/148 was initiated by the recording reasons and upon taking necessary approval from the competent authority notice under Section 148 of the Act dated 31.03.2019 was issued and served upon the assessee. No return in response to the said notice was filed ... assessee challenged the reopening of the assessment on account of reasons that the company was struck off from ROC w.e.f 06.07.2017 and therefore, notice under Section 148 of the Act issued upon a non-existent company is not valid. 4. None appeared on behalf of the assessee at the time

Ajay Duggal, New Delhi vs. Income Tax Officer 72(1), New Delhi

In the result, appeal of the assessee is partly allowed as

ITA 5612/DEL/2024[2016-17]Status: DisposedITAT Delhi30 Jul 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.5612/Del/2024 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Ajay Duggal Income Tax Officer, C-138, Vivek Vihar, Vs. Ward-72(1), Anand Vihar, S.O., Aayakar Bhawan, East Delhi. Delhi. Pan No.Aglpd6006C अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 151Section 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. A table representing ... 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

Ali Mohammad, Ghaziabad vs. ACIT, Circle-2(1)(1), Ghaziabad

In the result, appeal of the assessee is allowed

ITA 5608/DEL/2024[2014-15]Status: DisposedITAT Delhi30 Jul 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.5608/Del/2024 िनधा"रणवष"/Assessment Year: 2014-15 बनाम Ali Mohammad Acit, Mohalla Kot Kachchi Saray, Vs. Circle-2(1)(1), Murad Nagar, Ghaziabad, Ghaziabad. Uttar Pradesh. Pan No.Etopm2968E अपीलाथ" Appellant ""यथ"/Respondent

Section 144Section 147Section 148Section 151Section 3

notice shall be issued” reflects the intention of the legislature to indicate that prior approval is the sine qua non before issuance of notice under Section 148 of the Act. The purpose of insertion of expression ‘No notice shall be issued' before issuing a notice of re-assessment ... holding that sanction to be granted by the authority under Section 151 has to be prior in point of time of issuance of notice under Section 148 of the Act. 5 13. In the facts of the present case, it is clear from the digital signature on the notice issued

Suresh Chand, Gurgaon vs. ITO, Ward 4(1), Gurgaon

Appeal is allowed

ITA 4110/DEL/2024[2013-14]Status: DisposedITAT Delhi30 Jul 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 4110/Del/2024 : Asstt. Year : 2013-14 Suresh Chand, Vs Income Tax Officer, C/O Ca M R Sahu, House No. 651, Ward-4(1), 1St Floor, Sector-10A, Near G. D. Gurgaon, Goenka Public School, Gurgaon, Haryana-122016 Haryana-122001 (Appellant) (Respondent) Pan No. Aoopk7257H Assessee By : Sh. M. R. Sahu, Ca Revenue By : Sh. Mahesh Kumar Cit-Dr Date Of Hearing: 07.07.2025 Date Of Pronouncement: 30.07.2025 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2013-14, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1066753639(1) Dated 16.07.2024, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Mahesh Kumar CIT-DR

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

Scheme.—For the purpose of this Scheme,— (a)assessment, reassessment or re-computation 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