“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

Suresh, Pinjore vs. Income Tax Officer, Ward-4, Panchkula

In the result both the above appeals are allowed

ITA 1149/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh29 Jul 2025AY 2011-12

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Smt. Neelam Dhiman, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 68

raised the following grounds: 1. BECAUSE, while holding the assessment to be valid the Ld CIT(A) omitted to consider that no Notice under section 148 of the 'Act' was served upon the 'appellant' and ex- parte assessment was completed without serving any Notice under section 148 ... Department received AIR information about these deposits and initiated proceedings under Section 147 of the Income Tax Act, 1961, by issuing a notice under Section 148 dated 16.03.2018, as the assessee had not filed his return of income within the statutory period. Despite multiple notices under Section

Suresh, Pinjore vs. Income Tax Officer, Ward 4, Panchkula

In the result both the above appeals are allowed

ITA 1148/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh29 Jul 2025AY 2011-12

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Smt. Neelam Dhiman, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 68

Sachinkumar Premanandbhai Patel, Anand vs. The ITO, Ward-1, Anand

In the result, the appeal of the assessee is allowed

ITA 596/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2013-14

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2013-14 Sachinkumar Premanandbhai Patel Ito, Ward-1 Nr.Old Post Office Vs. Anand. Bhalej Anand Umreth, Gujarat Pan : Auhpp 8057 H (Applicant) (Responent) : Shri B.T. Thakkar, Ar Assessee By : Shri Amit Pratap Sigh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025

For Appellant: Shri Amit Pratap Sigh, Sr.DR

Section 144Section 147Section 148Section 253(5)Section 54

relevant period and failed to offer capital gain arising from such transfer. 3.2 Accordingly, proceedings under section 147 were initiated, and notice under section 148 was issued on 09.12.2019. In response, the assessee filed 3 return of income declaring total income of Rs.2,59,990/-. The AO, however, held that ... During the course of hearing, the learned Authorised Representative (AR) submitted that the Assessing Officer has committed a fundamental jurisdictional error in issuing notice under section 148 for A.Y. 2015–16 but proceeding to frame the assessment for A.Y. 2013–14, which is impermissible under the scheme

Parvinbanu Mayudin Kazi, Anand vs. The ITO, Ward-1 (Previously Ward-5), Anand

In the result, the appeal is allowed

ITA 595/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2011-12

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2011-12 Parvinbanu Mayudin Kazi Ito, Ward-1 50/51, Sabnam Society Vs. Anand. Nr. New Water Tank Anand, Gujarat. Pan : Awppk 5536 L (Applicant) (Responent) : Shri B.T. Thakkar, Ar Assessee By : Shri Amit Pratap Singh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025 आदेश/O R D E R आदेश आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 26.05.2023 Passed By The Commissioner Of Income-Tax (Appeals), Nfac, Delhi [“Cit(A)”], For A.Y. 2011–12, Confirming The Addition Of Rs.9,81,000/- Made By The Assessing Officer Under Section 69A Of The Income-Tax Act, 1961, In Respect Of Cash Deposits In Her Savings Bank Account Vide His Order Dated 26.12.2018 Passed Under Section 143(3) R.W.S. 147 Of The Act.

For Appellant: Shri Amit Pratap Singh, Sr.DR

Section 143(3)Section 147Section 148Section 151Section 271(1)(c)Section 69A

filed the original return of income. Proceedings under section 147 were initiated after recording reasons and obtaining 3 approval under section 151. Notice under section 148 was issued on 27.03.2018. The assessee filed return on 31.10.2018 declaring total income of Rs.1,74,244/-. The AO issued notices under sections

Yogesh Hargovindbhai Joshi L/H of Bhavnaben Y. Joshi, Ahmedabad vs. The ITO, Ward-6(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 520/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2012-13

Bench: Dr. Brr Kumar, Vice- & Ms.Suchitra R. Kambleassessment Year : 2012-13 Yogesh Hargovindbhai Joshi Vs. The Ito, Ward-6(1)(1) L/H. Of Bhavnaben Y. Joshi Ahmedabad. 8, Manav Pursusharth Society Opp: Hirabhai Tower Uttamnagar, Maninagar Pan : Adupj 2208 C (Applicant) (Responent) : Shri Parin Shah, Ar Assessee By Revenue By : Shri Abhijit, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 08/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025 आदेश/O R D E R आदेश आदेश आदेश

For Respondent: Shri Abhijit, Sr.DR

Section 10(38)Section 129Section 139Section 143(2)Section 143(3)Section 147Section 148Section 234ASection 250

year under consideration. After examining the returns filed by the assessee, the assessee’s case was reopened under section 147, and thereafter, issued notice under section 148 of the Act dated 30.3.2019. In response to the notice under section 148 of the Act dated 30.3.2019, the legal representative ... issued to the assessee on change of incumbent. The Legal representative (“L/R” for short) of the assessee filed objection against the issuance of notice under section 148 of the Act dated 30.3.2019. The objections of the assessee were disposed by a speaking order dated 11.7.2019. The L/R vide submissions dated

Madanlal Girdharilal Bugaliya, Ahmedabad vs. ITO Ward 1(2)(3), Ahmedabad

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 2024/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2010-11

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri B. P. Makwana, Sr. DRFor Respondent: Shri B. P. Makwana, Sr. DR

Section 143(1)Section 148Section 271(1)(c)Section 69

novo consideration in the interest of justice. 8. We further, note that so far as Ground No. 1 (challenging through issuance of notice under Section 148 of the Act) is concerned, the Counsel for the assessee submitted that he shall not be pressing this ground of appeal, and accordingly, Ground

Madanlal Girdharilal Bugaliya, Ahmedabad vs. ITO, Ward-1(2)(3), Ahmedabad

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 2023/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2010-11

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri B. P. Makwana, Sr. DRFor Respondent: Shri B. P. Makwana, Sr. DR

Section 143(1)Section 148Section 271(1)(c)Section 69

Mayankkumar Rameshchandra Bhatt, Vadodara vs. The Income Tax Officer, Ward-1(2)(1), Vadodara

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

ITA 1284/AHD/2024[2007-08]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2007-08

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2007-08 Mayankkumar Rameschandra Ito, Ward-1(2)(1) Bhatt Vs. Vadodara. B/202, Laljikrupa Society B/H. Mothers School Gotri Road, Baroda. Pan : Agypb 2066 R (Applicant) (Responent) : Shri Tushar Hemani, Sr.Advocate Assessee By Revenue By : Shri Umesh Kumar Agrawal, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 24/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29 /07/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 17.05.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”] By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], For The Assessment Year 2007–08, Arising Out Of The Reassessment Order Dated 27.03.2015 Passed Under Section 144 R.W.S. 147 Of The Act By The Income Tax Officer, Ward 4(2)(4), Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”].

For Respondent: Shri Umesh Kumar Agrawal, Sr.DR

Section 10(38)Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

Savings Bank Account purportedly maintained with Bank of India, Karelibaug Branch, during the financial year relevant to A.Y. 2007–08. The AO issued notice under section 148 of the Act on 19.03.2014, which was duly served upon the assessee on 21.03.2014. In response, the assessee submitted a letter dated

Shivratan Motilal Rathi HUF, Pune vs. ITO, Jalna

In the result, the appeal filed by the assessee in ITA

ITA 606/PUN/2025[2011-12]Status: DisposedITAT Pune29 Jul 2025AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.605 & 606/Pun/2025 िनधा"रण वष" / Assessment Years : 2008-09 & 2011-12 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By Shri Akhilesh Srivastva : Date Of Hearing 24.07.2025 : Date Of Pronouncement : 29.07.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2011-12 Respectively. 2. There Is Delay Of 64 Days In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeals Within The Prescribed Time Limit. Ld. Dr Has Not Raised Any Serious Objection To Condone The Delay, Therefore We Condone The Delay Of 64 Days & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.605/Pun/2025 For Assessment Year 2008-09 As The Lead Case For Adjudication.

For Appellant: Miss Smruti Sabnis

Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

into the above property has escaped assessment. Accordingly, after seeking approval u/s 151 of the IT Act for assessment year 2008- 09 a notice under section 148 was issued to the assessee & subsequently notices u/s 142(1) was also issued to the assessee. The Assessing Officer completed the assessment

Shivratan Motilalji Rathi HUF, Pune vs. ITO, Jalna

In the result, the appeal filed by the assessee in ITA

ITA 605/PUN/2025[2008-2009]Status: DisposedITAT Pune29 Jul 2025AY 2008-2009

For Appellant: Miss Smruti Sabnis

Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

Heena Irfan Bepari, Sangli vs. Income Tax Officer, Sangli

In the result, appeal of the assessee is partly allowed

ITA 1185/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jul 2025AY 2015-16

Section 148Section 148ASection 149Section 250Section 44A

invalid and hence needs to be quashed. ITA No.1185/PUN/2025 [A] 2. On the facts and circumstances of the case and in law, the notice under section 148 being without DIN, the same is invalid and hence the consequent assessment order passed by the AO is also invalid

Heena Irfan Bepati, Sangli vs. Income Tax Officer, Sangli

In the result, appeal of the assessee is partly allowed

ITA 1184/PUN/2025[2014-15]Status: DisposedITAT Pune29 Jul 2025AY 2014-15

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1183 & 1184 /Pun/2025 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15 Heena Irfan Bepari, V The Income Tax Officer, 661, Raviwar Peth, S Ward-5, Sangli. Madhavnagar, Sangli – 416416. Maharashtra. Pan: Bnepb9635A Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte– Ar Revenue By Shri Sandeep P Sathe –Jcit(Dr) Date Of Hearing 16/07/2025 Date Of Pronouncement 29/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 & 2014-15 Both Dated 24.03.2025 Respectively.For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal In Ita

Section 143(2)Section 148Section 148ASection 250

same is invalid and hence needs to be quashed. 2. On the facts and circumstances of the case and in law, the notice under section 148 being without DIN, the same is invalid and hence the consequent assessment order passed by the AO is also invalid. 3. On the facts ... Supreme Court in Rajeev Bansal (supra), we find that the Revenue had only 2 days (i.e., between 29/06/2021 to 30/06/2021) to issue notice under section 148 of the Act of the new regime in the present case, i.e. till 26/06/2022, after receipt of the response from the assessee on 24/06/2022

Heena Irfan Bepari, Sangli vs. Income Tax Officer, Sangli

In the result, appeal of the assessee is partly allowed

ITA 1183/PUN/2025[2013-14]Status: DisposedITAT Pune29 Jul 2025AY 2013-14

Section 143(2)Section 148Section 148ASection 250

M/S. Ashok Leyland Ltd., Chennai vs. DCIT, Ncc-8(1), Ltu-II, Chennai

In the result, appeal filed by the assessee is allowed

ITA 601/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Jul 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 147Section 148Section 32(1)(iia)

part of the petitioner to disclose fully and truly all material facts necessary for its assessment for the assessment years under consideration, the notice under section 148 of the Act having been issued after the expiry of a period of four years from the end of the relevant assessment years

Rehana Parveen, Mangalore vs. Income Tax Officer, Ward 6(3)(1), Bangalore

In the result, appeal of the assesseeis allowed

ITA 38/BANG/2025[2015-16]Status: DisposedITAT Bangalore29 Jul 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2015-16

For Appellant: Shri. Balram R Rao, AdvocateFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue

Section 148Section 148ASection 149

circumstances of the case, the learned CIT(A) failed to appreciate the fact that the Assessing Officer while issuing the notice under Section 148 A (b) of the Income Tax Act, 1961 [in short "the Page 2 of 5 Act"] had provided time of less than 7 days which ... assessee did not file its original return of income and the assessee has sufficient transaction s in her bank accounts. Therefore, a notice under section 148 of the Act was issued to the assessee on 31.03.2022. In response to the notice, assessee filed reply on 19.10.2022 declaring income of Rs.5

Indu Mahendra Shah (L/H of Late Shri Mahendra G. Shah), Mumbai vs. ITO, Ward-20(2)(2), Mumbai

In the result, the appeal filed by the assessee is allowed and the reassessment order passed under section 143(3) read with section 147 is quashed

ITA 855/MUM/2024[2012-13]Status: DisposedITAT Mumbai29 Jul 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 10(38)Section 143(1)Section 143(3)Section 147Section 148Section 69A

haste, failed to undertake the elementary task of verifying the return of income and the accompanying documents, and proceeded to issue the notice under section 148 solely on the strength of generic information received from the Investigation Wing. There is no material or factual nexus between the said information ... behest of investigative reports, but must form an independent belief on the basis of objective evaluation of facts, before issuing a notice under section 148. 11. Applying the aforesaid principles to the facts of the present case, we are constrained to hold that the reassessment proceedings have been initiated

Gajgamini Investment & Finance P. Ltd.. (Successor to Viloma Equity Services P. Ltd.), Andheri (East) vs. ITO Ward 11(3)(3), Mumbai, Aaykar Bhavan

In the result the appeal filed by the assessee stands allowed

ITA 5951/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Jul 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosaingajgamini Investment & Vs. Ito, Ward 11(3)(3) Finance P. Ltd., 429, 4Th Floor, Aaykar (Successor To Viloma Equity Bhavan, Mk Road, Services P. Ltd) Mumbai – 400020. Office No. 102, A Wing, 1St Floor, Mittal Commercial, Near Mittal Indl. Estate, Andheri Kurla Road – 400059. Pan/Gir No. Aabcg3951A (Applicant) (Respondent)

Section 115JSection 143(2)Section 143(3)Section 148Section 250

objection to reopening on various grounds. 2. The primary ground that has been raised is that the Income Tax Officer who issued the notice under section 148 of the Act, had no jurisdiction to issue such notice. According to Petitioner as per instruction No. 1/2011 dated 31st January, 2011 issued ... about Rs. 64,34,663/- and therefore, the jurisdiction will be that of DC/AC and not ITO. Mr. Jain submitted that since notice under section 148 of the Act has been issued by ITO, and not by DC/AC that is by a person who did not have any jurisdiction over

DCIT, New Delhi vs. M/S. Saamag Construction Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed as above

ITA 3738/DEL/2017[2006-07]Status: DisposedITAT Delhi29 Jul 2025AY 2006-07

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

Section 132(1)Section 148Section 153ASection 69C

jurisdictional issue i.e. the assumption of jurisdiction under section 148 of the Act in favour of the assessee by holding that the notice under section 148 of the Act for the relevant year issued on 19.03.2019 was barred by limitation. The relevant part of the impugned order reads as under ... attention the provisions of section 150 of the Act, which read as under: “150. (1) Notwithstanding anything contained in section 149, the notice under section 148 may be issued at any time for the purpose of making an assessment or reassessment or recompilation in consequence of or to give Saamag

Bhagwandas Jagdish Prasad, Bagbahara vs. Income Tax Officer, Mahasamund

In the result, appeal of the assessee is allowed

ITA 413/RPR/2025[2014-15]Status: HeardITAT Raipur28 Jul 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.412 & 413/Rpr/2025 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15 Bhagwandas Jagdish Prasad Petrol Pump, Main Road, Bagbahara-493 449 (C.G.) Pan: Aamfb0173H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Mahasamund (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 148

said decision, the Hon’ble Jurisdictional High Court had held as follows: “6…………. For issuance of notice under Section 148 of the I.T. Act, there should be tangible material and mandatory compliance of Section 147 of I.T. Act. Proceedings of reassessment has been initiated against company after lapse 5 Bhagwandas ... issuance of notice and provisions mentioned therein, in the opinion of this Court, there was no reason/ground available with Assessing Officer to issue notice under Section 148 of the I.T. Act. Issuance of notice under Section 148 of the I.T. Act to petitioner is not in accordance with the first

Bhagwandas Jagdish Prasad, Bagbahara vs. Income Tax Officer, Mahasamund

In the result, appeal of the assessee is allowed

ITA 412/RPR/2025[2013-14]Status: HeardITAT Raipur28 Jul 2025AY 2013-14

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 148