“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

Anil Kumar Parekh, Dhamtari vs. Income Tax Officer, Ward Dhamtari, Dhamtari

In the result, appeal of the assessee is allowed

ITA 194/RPR/2025[2013-14]Status: DisposedITAT Raipur28 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.194/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Anil Kumar Parekh C/O. Madhu Traders, Station Road, Dhamtari (C.G.)-493 773 Pan: Akepp0240E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Dhamtari (C.G.) ……""यथ" / Respondent

For Appellant: None (Adjournment Application)For Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 147Section 148Section 68Section 69C

which the assessee informed the Assessing Officer that the return originally filed should be treated as the return filed pursuant to the notice under section 148 of the Act. 13. In DIT v. Society for Worldwide Inter Bank Financial, Tele-2023 SCC OnLine Del 7382 communications', this court invalidated ... such claim. 10 Anil Kumar Parekh Vs. ITO, Ward-Dhamtari In view of the above, after receipt of return in response to notice under section 148, it shall be mandatory for the Assessing Officer to serve a notice under sub-section (2) of section 143 assigning reason therein...in absence

Rupesh Jaiswal, Dharampuri vs. Income Tax Officer, Indore

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

ITA 717/IND/2024[A.Y. 2017-18]Status: DisposedITAT Indore28 Jul 2025

Bench: B.M. Biyani & Shri Paresh M Joshirupesh Jaiswal, Income Tax Officer, बनाम/ 111, Azad Marg, Indore Vs. Dist. Dhar, Tehsil Dharampuri, Dharampuri (Pan: Akopj7192C) (Appellant) (Revenue) Assessee By Shri Venus Rawka & Ms. Eva Rawka, Ars Revenue By Shri Anoop Singh, Cit-Dr Date Of Hearing 22.07.2025 Date Of Pronouncement 28.07.2025 आदेश / O R D E R

Section 115BSection 142(1)Section 144Section 147Section 148Section 246ASection 250Section 253Section 69A

Based on definite information regarding cash deposits and withdrawals, the AO initiated reassessment proceedings under Section 147 by issuing a notice under Section 148. The reassessment proceedings were initiated correctly as per the provisions of the Act. The appellant did not respond to the initial notices issued under Section

Income Tax Officer 3(1), Bhopal, Metro Walk Building vs. Ramesh Kumar Sahu, Legal Heir of Smt. Rampyari Bai, Bhopal

In the result appeal of the Revenue is dismissed

ITA 509/IND/2023[2012-2013]Status: DisposedITAT Indore28 Jul 2025AY 2012-2013

Bench: Shri B.M. Biyani & Shri Paresh M Joshiincome Tax Officer 3(1), Ramesh Kumar Sahu बनाम/ Bhopal L/H Of Late Smt. Ram Vs. Pyari Bai, 127 New Market, T.T. Nagar, Bhopal (Pan: Anhps5515N) (Revenue/Appellant) (Assessee/Respondent) Assessee By S/Shri Ashish Goyal & N.D. Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.07.2025 Date Of Pronouncement 28.07.2025

Section 142(1)Section 144Section 147Section 148Section 253

para 14 of the judgment (supra) wherein in para 14 it is held as under :- “ 14. In view of the above, reopening notice under section 148 of the Act, 1961 issued in the name of a dead assessee is null and void being without jurisdiction. Recently this court ... Saxena case (supra) was identified as below:- 10. The issue which falls for consideration of this Court is as to whether the impugned notice under Section 148 of the Act of Page 13 of 17 Ramesh Kumar Sahu, L/H of Late Smt. Ram Pyari Bai ITA No.509/Ind/2023 - A.Y.2012-13

Binitaben Sandipkumar Patel, Vadodara vs. The Pr.CIT, Vadodara-1, Vadodara

The appeal of the assessee is allowed

ITA 702/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jul 2025AY 2018-19

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2018-19 Sejalben Patel The Pr.Cit-1 1049, Kantvalue Faliyu Vs. Vadodara. At & Po-Karkhadi Tal. Padra, Dist. Vadodara. Pan : Drhpp 9550 D Asstt.Year : 2018-19 Binitaben Sandipkumar Patel The Pr.Cit-1 Javla, Chotra Pase Vs. Vadodara. Savli, Dist. Vadodara. Pan : Cwopp 4609 Q (Applicant) (Responent)

For Appellant: Ms.Urvashi Sodhan, AR

Section 139(1)Section 144BSection 147Section 148Section 194Section 263Section 31Section 54

undertaken substantial high-value transactions during the relevant financial year. Based on such information, the Assessing Officer reopened the case by issuing a notice under section 148 of the Act on 31.03.2022, and subsequently, statutory notices under sections 143(2) and 142(1) were issued. The reasons recorded for reopening ... corresponding TDS credit of Rs.2,40,000/- under section 194-IA was reported. ITA No.701 & 702/Ahd/2025 3 3.2 The assessee, in response to notice under section 148, filed her return of income on 28.04.2022. The return was accompanied by supporting documents, including sale deeds, valuation reports from a registered valuer

Sejalben Patel, Vadodara vs. The Pr.CIT, Vadodara-1, Vadodara

The appeal of the assessee is allowed

ITA 701/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jul 2025AY 2018-19

For Appellant: Ms.Urvashi Sodhan, AR

Section 139(1)Section 144BSection 147Section 148Section 194Section 263Section 31Section 54

Dilip Roy, Jalpaiguri vs. ITO, Ward 1(1), Jalpaiguri

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 819/KOL/2025[2018-2019]Status: DisposedITAT Kolkata28 Jul 2025AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos.818 & 819/Kol/2025 Assessment Years: 2017-2018 & 2018-2019 Dilip Roy,……………….……………...….………Appellant Sipaipara, Shahudangi Hat, Jalpaiguri-735135, West Bengal [Pan:Ainpr9363C] -Vs.- Income Tax Officer,……………………...…….Respondent Ward-1(1), Jalpaiguri, Central Revenue Building, Race Course Road, Jalpaiguri-735101, W.B.

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 68

under section 148A(b) and order under section148A(d) was passed on 31.03.2022 in the absence of any explanation from the assessee. A notice under section 148 was issued on 31.03.2022 calling for the return of income with 30 days of receipt of the notice, but the assessee

Dilip Roy, Jalpaiguri vs. ITO, Ward 1(1), Jalpaiguri

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 818/KOL/2025[2017-2018]Status: DisposedITAT Kolkata28 Jul 2025AY 2017-2018

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 68

M/S. Amritlaxmi Vincom Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(3), Kolkata

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

ITA 2553/KOL/2024[2012-2013]Status: DisposedITAT Kolkata28 Jul 2025AY 2012-2013

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2553/Kol/2024 Assessment Year: 2012-2013 Amrit Laxmi Vincom Pvt. Ltd.,…………….…Appellant 23A, Netaji Subhash Road, Dalhousie, Room No. 10, 1St Floor, Kolkata-700001, West Bengal [Pan:Aaica5974A] -Vs.- Income Tax Officer,…………………..…………..Respondent Ward-4(3), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Sunil Surana, A.R., Appeared On Behalf Of The Assessee Shri L.N. Dash, Addl. Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 07, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 144Section 147Section 148

modus operandi. During the relevant year, the assessee has escaped the assessment within the meaning of section 147 of the Act. Accordingly, notice under section 148 of the Act was issued on 25.03.2019 after taking necessary approval of ld. Pr. CIT-2, Kolkata. The said notice was duly served upon ... proceeding is not in accordance with law since the ld. Assessing Officer has not obtained approval from the higher authorities before issuance of notice under section 148 of the Act. He further submitted that the said issue was raised before the ld. CIT(Appeals), but he has not adjudicated

Sri. Biligiriranganathswamy Multi Purpose Co-Operative Society, Chamarajanagar vs. Income Tax Officer, Ward-1, Chamarajanagar

In the result, appeal of the assessee is allowed

ITA 927/BANG/2025[2018-19]Status: DisposedITAT Bangalore28 Jul 2025AY 2018-19

Bench: Shri Prashant Maharishi, Hon’Ble

Section 133(6)Section 147Section 148Section 148ASection 151Section 69A

further cash withdrawal from the same bank of Rs.6,09,87,000/-, assessee has not filed any return of income. Therefore, notice under section 148 of the Act was issued on 06.04.2022 including the show cause notice was issued by the Ld. AO, however no response was received ... wherein it is specifically stated that approval of PCIT, Bengaluru-3 was obtained on 05.04.2022. He submits that in the notice under section 148 of the Act dated 06.04.2022 in Paragraph No. 3 it is specifically stated that approval of PCIT, Bengaluru-3, was obtained on 05.04.2022. He submits that

Shri Amit Mangilal Jain, Mumbai vs. ACIT, - 33(1), Mumbai

In the result, both the above appeals are allowed

ITA 3332/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Jul 2025AY 2010-11

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Naresh Jain & Shri Mahaveer Jain, ARsFor Respondent: Shri Ram Krishn Kedia, (Sr. DR)

Section 131Section 143(3)Section 147Section 148Section 153C

recompute the loss or the depreciation allowance or any other allowance or deduction for such assessment year and for which a prior notice under Section 148 would be required to be issued. Section 147 does not contemplate an eventuality which Section 153A or Section 153C contemplates, the basis of which

Sri Lanka Cricket, Sri Lanka vs. Assistant Commissioner of Income Tax (International Tax) Circle- 3 (1)(2), New Delhi

ITA 1603/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Jul 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 14Section 147Section 148Section 148ASection 154Section 234ASection 234BSection 270A

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘D': NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI

Jeet Kaur, Sainik Farm vs. Income Tax Officer Ward 19(3), Delhi

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

ITA 5512/DEL/2024[2013-14]Status: DisposedITAT Delhi28 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

Section 143(1)Section 148Section 148ASection 69

entire proceedings are void ab initio and liable to be quashed. 5. The subject reassessment proceedings are liable to be quashed as the notice under Section 148 was issued beyond the prescribed period of limitation. 6. The Ld. AO has grossly erred in raising the impugned demand upon the assessee ... declaring income of Rs.20,79,370/-. The ITR was processed under section 143(1) of the Act. Thereafter, reassessment proceedings were initiated vide notice under section 148 of the Act on the reasoning that the assessee had taken accommodation entry of Rs.59,24,700/- through penny stock of Presha Metallurgical

Koti Narasimha Reddy Guttikonda, Guntur vs. Principal Commissioner of Income Tax, Vijayawada

In the result, appeal of the assessee is allowed

ITA 332/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.332/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2016-17) Koti Narasimha Reddy Guttikonda Vs. Pr. Cit 1-99, Rudravaram – 522410 Siddhardha Public School Road Guntur District, Andhra Pradesh Mogalrajapurm Vijayawada – 520010 [Pan: Amcpg7882N] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri K.Siva Ram Kumar, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 147Section 148Section 148ASection 263Section 271(1)(c)

School Teacher at MPP School, Achampeta. The case was reopened based on the order under section 148A(d) of the Act, after issuing notice under section 148 of the Act. Subsequently, assessee filed his return of income on 26.11.2021 admitting total income at Rs.3,98,650/-. Ld. Assessing Officer [hereinafter ... assessee furnished his reply through his Authorized representative on 18.02.2025. Considering the submissions of the assessee that, assessee has challenged the issuance of notice under section 148 of the Act, Ld.Pr.CIT rejected the contentions of the assessee. Ld.Pr.CIT directed the Ld.AO to initiate penalty proceedings by setting-aside the assessment

Babu Rao Sahukari, Visakhapatnam vs. Income Tax Officer, Ward 2 (5), Visakhapatnam

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

ITA 327/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.327/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Babu Rao Sahukari Vs. Income Tax Officer – Ward – 2(5) 24-107-54/1 Visakhapatnam – 530020 C/O. Srikar Sai Medical Agencies Andhra Pradesh Gonthivanipalem Gajuwaka, Visakhapatnam – 530026 Andhra Pradesh [Pan:Efnps1341E] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri M. Muralidhar, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr.Ar

Section 142(1)Section 144Section 147Section 148Section 148ASection 69ASection 69C

notice and hence the Ld. AO proceeded to pass an order under section 148A(d) of the Act on 30.03.2022 and accordingly issued notice under section 148 of the Act on 30.03.2022 requiring the assessee to file the return of income within the specified date. Ld. AO as detailed ... order of the Ld. AO, assessee filed an appeal before Ld.CIT(A). Before Ld. CIT(A), assessee contested the jurisdiction for issuance of notice under section 148 of the Act. Assessee while acknowledging the date of service of the assessment order as 17.03.2023 filed the appeal before Ld.CIT

Nimmagadda Muralidhar, Nidadavole vs. The Income-Tax Officer, Ward - 1, Tanuku

In the result, appeal filed by the assessee is allowed

ITA 188/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.188/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Vs. Income Tax Officer-Ward – 1 Nimmagadda Muralidhar D.No. 3-123 Income Tax Office Samisragudem Village Aayakar Bhavan Near Zph High School Sajjapuram, Tanuku – 534211 Nidadavole Mandal Andhra Pradesh West Godavari District Andhra Pradesh [Pan:Anbpn7016M] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Gvn Hari, Advocate करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr. Ar

Section 139Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 69A

passed order under section 148A(d) of the Act on 06.04.2022 considering it as a fit case for issuance of notice under section 148 of the Act for the A.Y. 2015-16. Thereafter, the case was reopened and notice under section 148 of the Act was issued on 06.04.2022 requesting ... purpose of computation of seven days period. Further he also submitted that after passing the order under section 148A(d) of the Act notice under section 148 of the Act was issued on 06.04.2022 for the A.Y.2015-16 wherein the limitation expires on 31.03.2022 as per section

Deekonda Venkateswara Rao (HUF), Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

ITA 121/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2016-17

Bench: Us:

Section 143(2)Section 147Section 148Section 44ASection 68

substantial cash deposits of Rs. 1,11,27,529 with M/s. Citizen Cooperative Society Ltd., initiated proceedings under Section 147 of the Act. Notice under Section 148 of the Act, dated 23.01.2020 was issued to the assessee calling upon it to file its return of income for the subject year

Ganesh Transports, Vijayawada vs. The Assistant Commissioner of Income Tax, Circle-1(1), Vijayawada

In the result, appeal of the assessee is allowed

ITA 480/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No. 479/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2015-16) Ganesh Transports Vs. Income Tax Officer – Ward – 1(1) Cr Building, 1St Floor Annex Flat No. 504, Umamaheswari Towers West Ibrahimpatnam M.G. Road, Vijayawada – 520002 Vijayawada – 521456 Andhra Pradesh Andhra Pradesh [Pan:Aaifm6717G] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No. 480/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2015-16) Ganesh Transports Vs. Asst. Cit – Circle – 1(1) Cr Building, 1St Floor Annex Flat No. 504, Umamaheswari Towers West Ibrahimpatnam M.G. Road, Vijayawada – 520002 Vijayawada – 521456 Andhra Pradesh Andhra Pradesh [Pan: Aaifm6717G] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Mv Prasad, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr.Ar

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)

Multi Year NMS” data and subsequently reopened under section 147 of the Act after obtaining prior approval from the appropriate authorities. Thereafter notice under section 148 of the Act was issued on 29.03.2021 through e-proceedings. Assessee has not responded to the notice under section 148

Ganesh Transports, Vijayawada vs. The Income Tax Officer, Ward-1(1), Vijayawada

In the result, appeal of the assessee is allowed

ITA 479/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2015-16

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)

Bala Venkata Shiva Satya Naga Raju Mantena, Kalla Mandalam vs. Income Tax Officer, Ward-1, Bhimavaram

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

ITA 174/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2013-14

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.174/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2013-14) Bala Venkata Shiva Satya Naga Vs. Income Tax Officer – Ward – 1 Raju Mantena Bhimavaram 2-272/3, Malavani Thippa West Godavari District Andhra Pradesh Kaluvapudi – 534236 Kalla Mandalam West Godavari District Andhra Pradesh [Pan:Aocpm1009D] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri K.Siva Ram Kumar, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 147Section 148

Thereafter the case was reopened under section 147 of the Act after obtaining necessary approval from the competent authorities. Accordingly, notice under section 148 of the Act was issued on 31.03.2021. Subsequently, notice under section 142(1) of the Act was issued electronically on 16.11.2021, 11.01.2022 and 17.02.2022 requiring ... addition made by the Assessing Officer wherein the Ld.Authorised Representative [hereinafter “Ld.AR”] has challenged the jurisdiction of the Ld.AO in issuing the notice under section 148 of the Act. Ld.AR submitted that the assessee filed income tax return on 24.03.2022 along with the Tax Audit Report. He also further submitted

Ravinder Singh Thakkar, Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result the appeal of the assessee in ITA no

ITA 820/JPR/2025[2019-20]Status: DisposedITAT Jaipur25 Jul 2025AY 2019-20

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Gorav Avasthi, JCIT

Section 139Section 143(3)Section 147

taxmann.com 225 (Bombay), has held that there is no question of concurrent jurisdiction of JAO and FAO for issuance of reopening notice under section 148 or even for passing assessment or reassessment order and it is only FAO which could issue notice under section 148 ... sustainable. Dosch Pharmaceutical (P.) Ltd. v Income-tax Officer [2024] 166 taxmann.com 216 (Bombay) Held: Only Faceless Assessing Officer can issue notice under section 148 and not Jurisdictional Assessing Officer. Jatinder Singh Bhanguv. Union of India [2024] 165 taxmann.com 115 (Punjab & Haryana) Held: Scheme of faceless assessment applies from stage