← All Phrases

“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

Shailesh Asalraj Jain, Mumbai vs. Principal Commissioner of Income Tax, Mumbai 20, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2559/MUM/2025[2018-2019]Status: DisposedITAT Mumbai24 Feb 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19

For Appellant: Mr. Devendra JainFor Respondent: 03/12/2025
Section 147Section 148ASection 263

were initiated. An order under section 148A(d) was passed, followed were initiated. An order under section was passed, followed by issuance of notice under section 148 on 19.04.2022 19.04.2022. by issuance of notice under section 4.1 In response, the assessee filed a return rei In response, the assessee filed ... primary legal contention advanced by the assessee in additional ground is that the notice under section additional ground is that the notice under section 148 148 was issued without sanction from the competent authority as mandated under without sanction from the competent authority as mandated under without sanction from

Joydeep Mukherjee, Presently Residing at Usa vs. DCIT, Intl Taxation Circle 1(2), Bangalore, Bmtc Building, Koramangala

The appeal of the assessee is allowed for statistical purposes

ITA 2017/BANG/2025[2018-19]Status: DisposedITAT Bangalore23 Feb 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19 Joydeep Mukherjee, Vs. The Deputy Commissioner A 202, Prestige St. Johns Woods Of Income Tax Apt., 80, St. Johns Cross Road, International Taxation, Circle 1(2), Bengaluru South 560 029. Bangalore. Pan: Aawpm 7656E

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri K. Saravanan, Addl.CIT(DR)(ITAT), Bengaluru
Section 139Section 144Section 147Section 148Section 270ASection 276C

purchase of immovable properties of ₹ 9,879,309 during the financial year 2017 – 18 relevant to the impugned assessment year. 4. Accordingly the notice under section 148 was issued on 7 April 2022 in response to which the assessee filed return of income on 23 April 2023 at a total ... under section 139 (4) of the Act and the return filed by the assessee Page 3 of 9 is subsequently in response to notice under section 148 of the Act penalty proceedings under section 270A of the Act were initiated. 6. In response to the above penalty show cause notice

Sadruddin Noorudin Tejani, Mumbai vs. Income Tax Officer, Ward 26(2)(1), Mumbai

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

ITA 8621/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Feb 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2018-19

Section 144BSection 147Section 148Section 50C

Sadruddin Noorudin Tejani 6. Before us, the Ld. AR primarily challenged the validity of the reassessment proceedings by contending that the notice under section 148 of the Act was issued without proper approval of the prescribed authority. Alternatively, it was submitted that the order ... does indicate lack of due diligence. At the same time, we note that the legal ground relating to the sanction for issuance of notice under section 148 of the Act was not raised before the Ld. CIT(A), and the relevant details regarding such sanction are also not clearly discernible

Dwarka Cement Works Limited(Converted Into Dwarka Cement Works LLP W.E.F 15-09-2022), Mumbai vs. The Income Tax Officer, Ward-6(2)(1), Mumbai

ITA 6706/MUM/2025[2015-2016]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-2016

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 139(1)Section 143(3)Section 148Section 250Section 271(1)(c)Section 274

assessment was completed under section 143(3) on 28.12.2017 accepting the returned loss. 3. Subsequently, the case was reopened by issuance of notice under section 148 dated 29.07.2022. In response thereto, the assessee filed return of income on 26.08.2022 disallowing the claim of bad debts amounting to Rs. 1.18 crores ... Assessing Officer, the amounts were in the nature of capital expenditure and were not allowable as business expenditure. Upon issuance of notice under section 148 of the Act, the assessee filed its return of income in response thereto and disallowed the entire claim of bad debts. 5. The reassessment

DCIT, Central Circle 7(1), Mumbai vs. Balaji Bullions and Commodities India Private Limited, Mumbai

ITA 3915/MUM/2025[2017]Status: DisposedITAT Mumbai23 Feb 2026

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 131Section 133ASection 143(1)Section 147Section 148

prima facie belief that income chargeable to tax had escaped assessment. Consequently, reasons were recorded under section 147 of the Act, and notice under section 148 was issued on 30.03.2021. The notice was duly served, and in response, the assessee filed its return of income on 29.04.2021, reiterating the loss

Balaji Bullions and Commodities India Private Limited, Mumbai vs. DCIT Central Circle 7(1), Mumbai

The appeal of the Revenue is allowed for statistical purposes

ITA 3755/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Sharwan Kumar Jha, Adv
Section 133ASection 143(1)

Consequently, reasons were recorded under escaped assessment. Consequently, reasons were recor escaped assessment. Consequently, reasons were recor section 147 of the Act, and notice under section 148 was issued on section 147 of the Act, and notice under section 148 was issued on section 147 of the Act, and notice

Nitesh Agarwal, Agra vs. Income Tax Officer-2(1)(3), Agra

ITA 501/AGR/2025[2012-13]Status: DisposedITAT Agra20 Feb 2026AY 2012-13

Bench: : Shri S. Rifaur Rahman, Accoutant Member Nitesh Agarwal Vs Income Tax 29/81, Lakshmi Palace, Officer-2(1) (3), Namakkimandi, Agra- Agra 282003 Pan No Abnpa2197G Appellant Respondent

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 148Section 178Section 234ASection 234BSection 250(6)

BECAUSE, No Notice under section 178 of the ‘Act’ was served upon the ‘appellant’ and ex-parte assessment was completed without serving any Notice under section 148 of the ‘Act’ render the Assessment Order void-ab-initio. BECAUSE, the purported ‘Reasons’ as reproduced in the Assessment Order are No ‘Reasons ... application of mind on part of the ‘AO’ to show that any Income liable for Tax has escaped Assessment warranting recourse to Notice under section 148 of the Act. BECAUSE, the alleged escapement is based on incorrect assumption of fact that ‘appellant’ has not filed Return of Income

Birju Saw, Hazaribag vs. ITO, Hazaribag

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

ITA 359/RAN/2025[2013-14]Status: DisposedITAT Ranchi20 Feb 2026AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Birju Saw, I.T.O., S/O-Jitu Saw, Oreya, Hazaribagh. Vs. Hazaribagh-825303 (Jharkhand) Pan No. Bppps 3798 E Appellant/ Assessee Respondent/ Revenue

Section 142(1)Section 144BSection 147Section 148

case of the assessee was reopened under Section 147 of the Income Tax Act, 1961 (in short, the Act) and notice under Section 148 of the Act was issued. In response to the notice under Section 148 of the Act, the assessee did not file his return of income. Notice

Priya Pahwa, Ludhiana vs. Income Tax Officer, Ludhiana

In the result, appeal of the assessee is allowed

ITA 1112/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh20 Feb 2026AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1112/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 Priya Pahwa, The Ito, 66-D, Model Town Extension, Vs Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Bmtpp8544G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Ms. Rano Jain, Advocate & Ms. Mansi Jain, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 20.02.2026

For Appellant: Ms. Rano Jain, Advocate and Ms. Mansi Jain, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 148Section 148ASection 151

Section 151 has a direct bearing, therefore, we take note of both these clauses : 148A.The Assessing Officer shall, before issuing any notice under section 148,— (a)conduct any enquiry, if required, with the prior approval of specified authority, with respect to the information which suggests that the income chargeable ... basis of material available on record including reply of the assessee, whether or not it is a fit case to issue a notice under section 148, by passing an order, with the prior approval of specified authority, within one month from the end of the month in which the reply

Rohitkumar Chinubhai Modi, Ahmedabad vs. The ACIT, Cir. 5(2) Now DCIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is hereby dismissed

ITA 1961/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

completed on 17.12.2014 determining the total income at Rs.45,44,450/-Once again, the Assessing Officer initiated reassessment proceedings by issuing notice under section 148 on 23.03.2016 after recording reasons and obtaining approval as required under the Act. Since the assessee did not file a return in response ... notice under section 148 of the Act, a notice under section 142(1) read with section 148 of the Act dated 21.06.2016 was issued. In response, the assessee requested that the original return filed on 19.03.2010 be treated as the return filed in response to notice under section 148

Saurabhbhai Rohitbhai Modi, Ahmedabad vs. The ACIT, Cir. 5(2) Now DCIT, Circle-2(1)(1), Ahmedabad

The appeal of the assessee is hereby dismissed

ITA 1960/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Satish Solanki, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 143(3)Section 147Section 148Section 263

completed on 17.12.2014 determining the total income at Rs.45,44,450/-Once again, the Assessing Officer initiated reassessment proceedings by issuing notice under section 148 on 23.03.2016 after recording reasons and obtaining approval as required under the Act. Since the assessee did not file a return in response ... notice under section 148 of the Act, a notice under section 142(1) read with section 148 of the Act dated 21.06.2016 was issued. In response, the assessee requested that the original return filed on 19.03.2010 be treated as the return filed in response to notice under section 148

M/S.Wellknown Polyesters Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 4(3)(1), Mumbai

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

ITA 8704/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 147Section 148Section 148ASection 151

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 assessees from harassment resulting from the mechanical reopening of assessments Sri krishna ... 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

ITO-23(3)(6).Mumbai, Mumbai vs. Rajeshwar Bullion Trading, Mumbai

In the result, the appeal is dismissed

ITA 6132/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)
Section 115BSection 147Section 68

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 ... 148A(b) – to provide an opportunity of hearing to the assessee by serving upon them a show cause notice as to why a notice under Section 148 should not be issued based on the information that suggests that income chargeable to tax has escaped assessment. It must be noted that

M/S. Rajeshwar Bullion Trading, Mumbai vs. Asst. CIT, Circle 23(3), Mumbai

In the result, the appeal is dismissed

ITA 5754/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)
Section 115BSection 147Section 68

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 ... 148A(b) – to provide an opportunity of hearing to the assessee by serving upon them a show cause notice as to why a notice under Section 148 should not be issued based on the information that suggests that income chargeable to tax has escaped assessment. It must be noted that

DCIT 2(3)(1), Mumbai vs. Tata Steel Ltd, Mumbai

In the result, appeal of the Revenue is dismissed and that of the assessee is allowed

ITA 3555/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09
For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

sanction under the proviso to sub-section (1) of Section 151 of the Chief Commissioner to the issue of the Notice under Section 148 had not been obtained. or (iii) The Ld AO did not have any "reason to believe" that any income chargeable to tax had escaped assessment, within ... above paras for the purpose of assessment. Further the escapement of income/ under assessment of income is more than Rs. 1 lakh A notice under Section 148 is therefore issued to bring to tax escaped income attributable to above excess mining as well as any other income which

Tata Steel Ltd, Mumbai vs. Asst CIT 2(3), Mumbai

In the result, appeal of the Revenue is dismissed and that of the assessee is allowed

ITA 3294/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09
For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

sanction under the proviso to sub-section (1) of Section 151 of the Chief Commissioner to the issue of the Notice under Section 148 had not been obtained. or (iii) The Ld AO did not have any "reason to believe" that any income chargeable to tax had escaped assessment, within ... above paras for the purpose of assessment. Further the escapement of income/ under assessment of income is more than Rs. 1 lakh A notice under Section 148 is therefore issued to bring to tax escaped income attributable to above excess mining as well as any other income which

Yash Kumar Goyal, Gwalior vs. DCIT/ACIT 2(1), Gwalior

In the result, both appeals filed by the assessee are allowed

ITA 519/AGR/2025[2013-14]Status: DisposedITAT Agra19 Feb 2026AY 2013-14

Bench: : Shri S. Rifaur Rahman

Section 143(3)Section 147Section 148Section 153ASection 153CSection 271(1)(c)Section 274Section 50C

cost of acquisition was a bona fide and inadvertent clerical mistake, which was voluntarily corrected by filing a revised return in response to notice under Section 148. 6. That the penalty order is vitiated by non-application of mind and mechanical satisfaction, as the AO merely reproduced the assessment findings

Yash Kumar Goyal, Gwalior vs. DCIT/ACIT 2(1), Gwalior

In the result, both appeals filed by the assessee are allowed

ITA 518/AGR/2025[2012-13]Status: DisposedITAT Agra19 Feb 2026AY 2012-13

Bench: : Shri S. Rifaur Rahman

Section 143(3)Section 147Section 148Section 153ASection 153CSection 271(1)(c)Section 274Section 50C

cost of acquisition was a bona fide and inadvertent clerical mistake, which was voluntarily corrected by filing a revised return in response to notice under Section 148. 6. That the penalty order is vitiated by non-application of mind and mechanical satisfaction, as the AO merely reproduced the assessment findings

Ramjidas Budhraja Charitable Trust (Sgm), Chhindwara vs. Income Tax Officer Exemption, Jabalpur

In the result, the appeal of the assessee is dismissed

ITA 235/JAB/2025[2015-16]Status: DisposedITAT Jabalpur19 Feb 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 10Section 11Section 11(2)Section 143(1)Section 143(3)Section 147Section 148

notice was issued on 02.01.2018 fixing the case on 15.01.2018 which was obviously barred by limitation and, therefore, the Assessing Officer issued a notice under Section 148 on 28.03.2018 that was served on the assessee on 31.03.2018. In compliance to said notice the assessee submitted acknowledgement of return for assessment ... Assessing Officer. In this case it is pertinent to mention here that in the assessment order learned Assessing Officer has mentioned that a notice under Section 148 dated 06.12.2017 was issued to the assessee, however, no such notice was ever received by the assessee and if that is true then

Sudhansu Ranjan Nayak, Bhubaneswar vs. Income Tax Officer Ward 5(1), Bhubaneswar

In the result, appeal of the assessee is allowed

ITA 754/CTK/2025[2018-19]Status: DisposedITAT Cuttack19 Feb 2026AY 2018-19

Bench: Shri George Mathan & Shri Madhusudan Sawdiaआयकर अपील सं/Ita No.754/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2018-2019) Sudhansu Ranjan Nayak, Vs Ito Ward-5(1), Bhubaneswar At Plot No.176, District Center Chandrasekharpur, Bhubaneswar Odisha-751016 Pan No. : Ajmpn 2651 D (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri P.K.Mishra, Narahari Swain & Himansu Bhusan Jena, Advocates राज"व क" ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 19/02/2026 घोषणा क" तार"ख/Date Of Pronouncement : 19/02/2026

For Appellant: Shri P.K.Mishra, Narahari Swain &For Respondent: Shri Vijay Singh, Sr. DR
Section 147Section 148Section 148A

issued, or such time, as may be extended by him on the basis of an application in this behalf, as to why a notice under section 148 should not be issued on the basis of information which suggests that income chargeable to tax has escaped assessment in his case ... appropriate order within a period of four weeks. In the event the AO considers that it is a fit case for issuing notice under Section 148 of the Act, necessary approval shall be obtained from the concerned Chief Commissioner of Income Tax as was the requirement at the material time