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“notice under section 148”

ReassessmentSection 148Section 1487,377 judgments

The decision most relied on for notice under section 148 is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on notice under section 148

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

CIT v. Sinhgad Technical Education Society
397 ITR 344 · 2017 · Supreme Court
1,589
citing judgments

For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

Union of India v. Rajeev Bansal
469 ITR 46 · 2024 · Supreme Court
713
citing judgments

The legal fiction created by the Ashish Agarwal judgment stops the limitation clock for Section 148 notices from the date of the deemed notice. Orders issued without proper jurisdiction, or those inconsistent with statutory prescriptions, are a nullity, and there can be no waiver of such fundamental jurisdictional requirements.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

Tin Box Company v. CIT
249 ITR 216 · 2001 · Supreme Court
624
citing judgments

When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.

Judgments citing notice under section 148

Nkg Infrastructure Limited, New Delhi vs. DCIT, Central Circle-27, Delhi

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is dismissed

ITA 4749/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Jun 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Rajat Jain, CAFor Respondent: Shri Sunil Kumar Yadav, CIT DR
Section 143(2)Section 143(3)Section 148Section 153ASection 68Section 69C

well considered in the original assessment proceedings itself. Hence, initiation of the re-assessment proceedings under Section 147 by issuing a notice under Section 148 merely because of the fact that now the Assessing Officer is of the view that the deduction under Section 10A was allowed in excess

Gram Vikas Trust, Berhampur vs. ITO, Exemption Ward, Berampur

In the result, both the appeals filed by the assessee for AYs 2014-

ITA 437/CTK/2024[AY 2015-16]Status: DisposedITAT Cuttack12 Jun 2025

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 11(2)Section 119(2)(b)Section 143(1)(a)Section 154Section 234BSection 250

extends the time as permitted under section 139(1). In the present case, a return of income filed consequent to a re-opening notice under section 148 is to be treated as a return required to be filed under section 139. [Para11] The revenue accepts that even if the Form

Gram Vikas Trust, Berhampur vs. ITO, Exemption Ward, Berampur

In the result, both the appeals filed by the assessee for AYs 2014-

ITA 436/CTK/2024[AY 2014-15]Status: DisposedITAT Cuttack12 Jun 2025

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 11(2)Section 119(2)(b)Section 143(1)(a)Section 154Section 234BSection 250

extends the time as permitted under section 139(1). In the present case, a return of income filed consequent to a re-opening notice under section 148 is to be treated as a return required to be filed under section 139. [Para11] The revenue accepts that even if the Form

Sreekumara Samajam, Thrissur vs. ITO, Exemption Ward, Thrissur

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

ITA 1116/COCH/2024[2016-17]Status: DisposedITAT Cochin12 Jun 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaassessment Years: 2016-17 Sreekumara Samajam Ito, Exemption Ward, V. Thrissur Xxi/230 S Paliyamthuruth Anapuzha, Kodungallur Thrissur-680667, Kerala. Pan : Aafts2292H. (Appellant) (Respondent) Appellant By : Smt. Nivedita A Kamath, Adv. Respondent By : Smt. Leena Lal, Snr Ar. Date Of Hearing : 05.06.2025 Date Of Pronouncement : 12.06.2025 O R D E R Per Sonjoy Sarma: This Appeal Is Filed By The Assessee Against The Order Dated 06.11.2024 By The National Faceless Appeal Centre (Hereinafter Referred To As ‘Cit(A)’] For The Assessment Year 2016–17. 2. Brief Facts Of The Case Are That The Assessee Is Registered As A Society Under The Travancore-Cochin Literary, Scientific & Charitable Societies Registration Act, 1955, On 02.07.2009. It Is Also Registered Under Section 12A Of The Act With The Commissioner Of Income Tax, Thrissur & Claimed To Function As A Religious & Charitable Society. The Assessee Filed Its Return Of Income For A.Y. 2016–17 Declaring ‘Nil’ Income. The Assessee Was Engaged In Conducting Kuri Business & Money-Lending Business

For Appellant: Smt. Nivedita A Kamath, AdvFor Respondent: Smt. Leena Lal, Snr AR
Section 11Section 12ASection 142(1)Section 147Section 148Section 2(15)

loss could not be set off against such other income. Accordingly, the case was reopened under Section 147, with prior approval, by issuing notice under Section 148. The assessee failed to file a proper return in response, though a statement of computation of income and financials (P&L, balance sheet

Jitendra Kumar Soni, Jabalpur vs. ACIT Central Circle, Jabalpur

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

ITA 112/JAB/2025[2019-20]Status: DisposedITAT Jabalpur11 Jun 2025AY 2019-20

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2019-20 Jitendra Kumar Soni Acit-Central Circle V. 1, Silondi, Sihora, Jabalpur, 291 Ramnath Building, Madhya Pradesh-482002. Napier Town, Jabalpur. Pan:Cmbps6039Q (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Adv Respondent By: Shri Shravan Kumar Meena, Cit(Dr) Date Of Hearing: 23 05 2025 Date Of Pronouncement: 11 06 2025 O R D E R

For Appellant: Shri Sapan Usrethe, AdvFor Respondent: Shri Shravan Kumar Meena, CIT(DR)
Section 129Section 148Section 151Section 48

Income tax (Appeal) Raipur - 3 was not justified in dismissing the appeal without considering that the assessing officer erred in issuing the notice under section 148 of the Act is without Jurisdiction as the approval was taken from incompetent authority and after amendment in section 148 from 01.04.2021 approval should

Saif Ali Mansoor Ali Khan Pataudi, Mumbai vs. CIT (Appeals)- Delhi, Mumbai

In the result, the assessee succeeded on primary submission of ld

ITA 2131/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Jun 2025AY 2016-17

Bench: Shri Pawan Singh & Smt. Renu Jauhri(Physical Hearing) Saif Ali Mansoor Ali Khan Pataudi Cit(A), Nfac, Delhi/ Acit, Flat No. 1001/02, Fortune Heights, 29Th Vs Circle-16(1), Mumbai Road, Bandra West, Mumbai-400050. [Pan No. Aahpk0520E] Appellant / Assessee Respondent / Revenue Assessee By Shri K.K. Lalkaka, Ca Revenue By Ms. Sujatha Iyangar, Sr. Dr Date Of Institution Of Appeal 28.03.2025 Date Of Hearing 02.06.2025 Date Of Pronouncement 11.06.2025 Order Under Section 254(1) Of Income Tax Act

Section 148Section 149(1)(b)Section 151Section 155Section 251Section 254(1)

assessee submits that apart from challenging the validity of addition, the assessee has challenged the validity of issuance of notice under section 148 and its approval under section 151 of Income Tax Act. The ld. AR of the assessee submits that case of assessee for assessment year ... reopened by issuing notice under section 148 dated 24.08.2022. Copy of 2 Saif Ali Mansoor Ali Khan Pataudi notice under section 148 is filed on record. The ld. AR of the assessee by referring contents of para 3 of notice under section 148 submits that such notice was issued with

DCIT, Central Circle 1, Rajkot vs. Shri Mukesh Manekchand Sheth, Rajkot

ITA 724/RJT/2024[2017-18]Status: DisposedITAT Rajkot10 Jun 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 145(3)Section 147Section 148

regarding unaccounted part of the aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act, has been issued on 23-02-2023, to the assessee. In response to the notice issued under section 148 ... assessing officer has also observed that search was carried at the assessee's premises on 24-08-2021 and pursuant to the search, notice under Section 148 of the Act was issued in case of assessee. As search was carried out in the case of assessee after

DCIT, Central Circle 2, Rajkot vs. Shri Mukesh Manekchand Sheth, Rajkot

ITA 723/RJT/2024[2016-17]Status: DisposedITAT Rajkot10 Jun 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 145(3)Section 147Section 148

regarding unaccounted part of the aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act, has been issued on 23-02-2023, to the assessee. In response to the notice issued under section 148 ... assessing officer has also observed that search was carried at the assessee's premises on 24-08-2021 and pursuant to the search, notice under Section 148 of the Act was issued in case of assessee. As search was carried out in the case of assessee after

Mukesh Manekchand Sheth, Rajkot vs. The DCIT-ACIT, Central Circle -2, Rajkot.

ITA 581/RJT/2024[2016-17]Status: DisposedITAT Rajkot10 Jun 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 145(3)Section 147Section 148

regarding unaccounted part of the aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act, has been issued on 23-02-2023, to the assessee. In response to the notice issued under section 148 ... assessing officer has also observed that search was carried at the assessee's premises on 24-08-2021 and pursuant to the search, notice under Section 148 of the Act was issued in case of assessee. As search was carried out in the case of assessee after

Mukesh Manekchand Sheth, Rajkot vs. The DCIT-ACIT, Central Circle -2, Rajkot

ITA 547/RJT/2024[2019-20]Status: DisposedITAT Rajkot10 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri D.M Rindani, Ld. A.RFor Respondent: Shri Sanjay Punglia, Ld.CIT (DR)
Section 145(3)Section 147Section 148

regarding unaccounted part of the aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act, has been issued on 23-02-2023, to the assessee. In response to the notice issued under section 148 ... assessing officer has also observed that search was carried at the assessee's premises on 24-08-2021 and pursuant to the search, notice under Section 148 of the Act was issued in case of assessee. As search was carried out in the case of assessee after

Mukesh Manekchand Sheth, Rajkot vs. The DCIT-ACIT, Central Circle-2, Rajkot

ITA 546/RJT/2024[2018-19]Status: DisposedITAT Rajkot10 Jun 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 145(3)Section 147Section 148

regarding unaccounted part of the aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act, has been issued on 23-02-2023, to the assessee. In response to the notice issued under section 148 ... assessing officer has also observed that search was carried at the assessee's premises on 24-08-2021 and pursuant to the search, notice under Section 148 of the Act was issued in case of assessee. As search was carried out in the case of assessee after

Mukesh Manekchand Sheth, Rajkot vs. The DCIT-ACIT, Central Circle-2, Rajkot

ITA 545/RJT/2024[2017-18]Status: DisposedITAT Rajkot10 Jun 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 145(3)Section 147Section 148

regarding unaccounted part of the aforementioned transactions pertaining to the assessee have been gathered from the seized material during the search operation, a notice under section 148 of the Act, has been issued on 23-02-2023, to the assessee. In response to the notice issued under section 148 ... assessing officer has also observed that search was carried at the assessee's premises on 24-08-2021 and pursuant to the search, notice under Section 148 of the Act was issued in case of assessee. As search was carried out in the case of assessee after

Dashrathbhai Madhubhai Jadav, Ahmedabad vs. ITO, Ward-3(3)(1), Ahmedabad

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

ITA 653/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 653/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Dashrathbhai Madhubhai Jadav, The Income Tax Officer, At Post Khoraj Gam, बनाम/ Ward-3(3)(1), V/S. Taluka Sanand, Ahmedabad. Ahmedabad-380001. (Gujarat) "थायी लेखा सं./Pan: Aotpj7754H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Mehul Ranpura, Ar Revenue By : Shri R P Rastogi, Cit-Dr

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri R P Rastogi, CIT-DR
Section 144Section 147Section 148Section 250

appearing in AIR/CIB/TDS databases for F.Y. 2014–15, the Assessing Officer formed a belief that income chargeable to tax had escaped assessment. Consequently, notice under section 148 was issued on 31.03.2022. Despite issue of notices under sections 142(1) and 143(2), there was no compliance from the assessee

Irm Private Limited, Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

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

ITA 1590/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2011-12

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, SR-DR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 14ASection 194HSection 194J

before the Commissioner of Income-tax (Appeals), which was allowed, and the additions were deleted. Subsequently, the case was reopened by issuance of notice under section 148 of the Act dated 31.03.2018, purportedly on the ground that income had escaped assessment within the meaning of section ... inputs, the AO formed a belief that income to the extent of Rs. 70,59,579/- had escaped assessment and proceeded to issue notice under section 148 of the Act on 31.03.2018. In response, the assessee submitted that it had already filed return of income for the relevant year

Rana Iqbal Singh, V. Dosanjh Kalan, Phillaur vs. Income Tax Officer Ward-1, Phagwara

In the result, appeal of the Assessee stands partly allowed

ITA 496/ASR/2024[2013-2014]Status: DisposedITAT Amritsar09 Jun 2025AY 2013-2014

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 496/Asr/2024 निर्धारण वर्ा / Assessment Year : 2013-14 Rana Iqbal Singh, बनाम The Ito, Ward-1, Village Dosanjh Kalan, Assessment Unit, Tehsil Phillaur Delhi Distt. Jalandhar 144502 स्थधयी लेखध सं./Pan No: Ctops8735D अपीलधथी/Appellant प्रत्यथी/Respondent

For Appellant: Sh. Sudhir Sehgal &For Respondent: Sh. Manpreet Singh Duggal, Sr.DR
Section 142(1)Section 144BSection 147Section 148Section 60Section 68

case on the file. 2. That the Ld. CIT(A) gravely erred, in sustaining the reassessment proceedings under Section 147 and issue of notice under section 148 as the AO wrongly assumed jurisdiction to frame the reassessment. 3. That the Ld. CIT(A) erred in sustaining the reassessment proceedings

Shri Narendra Dharamdas Gidwani, Anjar Kutch vs. The Addl. CIT, NFAC, New Delhi

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

ITA 220/RJT/2023[2015-16]Status: DisposedITAT Rajkot09 Jun 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 220/Rjt/2023 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Narendra Dharamdas Gidwani, The Commissioner Of Income Vs. Plot No. 29, Survey No. 193/1, Maitru Tax(Appeals), Residency Meghpar Borichi, Anjar, National Faceless Appeal Centre Kutch, (Nfac), Delhi, Income Tax Gujarat - 370110 Department, Ministry Of Finance, Government Of India "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akmpg6386M (Appellant) (Respondent) Appellant By : Shri Chiranjeev Tandon, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 26/03/2025 Date Of Pronouncement : 09/06/2025 आदेश / O R D E R Per D. M. Sinha, Jm:

For Appellant: Shri Chiranjeev Tandon, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 147Section 269Section 269SSection 270ASection 69A

income regularly. The appellant filed return of income for assessment year 2015-16 on September 4, 2015. Thereafter, the assessing officer issued Notice under Section 148 of the Income Tax Act, 1961 [IT Act on March 31, 2021. In response, the Appellant vide Letter dated April 15. 2021 requested ... opening of assessment. However, the assessing officer did not reply. The Appellant filed same return on April 16, 2021 in response to Notice under Section 148 of IT Act. That assessing officer issued Notice under Section 143(2) read with 147 of IT Act thereby calling upon the Appellant

Deputy Commissioner of Income Tax, Central Circle-2(1), Nagpur vs. M/S. Aakar Hotels, Nagpur

In the result, appeal of the revenue is dismissed

ITA 47/NAG/2023[2013-14]Status: DisposedITAT Nagpur09 Jun 2025AY 2013-14

Bench: Shri V. Durga Rao, Hon'Ble & Shri K.M. Roy, Hon'Ble Accountant, Member

Section 147Section 148

Hotels to M/s PNB Construction company for a consideration of Rs.3,30,00,000/- on 20.02.2016 vide its assignment deed. In compliance to notice under section 148 of the Act, assessee filed NIL return of income for the year under consideration i.e. A. Y. 2016-17. Assessing Officer concluded ... 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

Atul Manoharrao Yamsanwar, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Nagpur

In the result, appeal of the Assessee is allowed

ITA 249/NAG/2022[2013-14]Status: DisposedITAT Nagpur09 Jun 2025AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri K.M. Roy, Hon’Ble Accountant, Member Atul Manoharrao Yamsanwar V. Acit – Central Circle – 2(1) Plot No. 33, Manoharrao Room No. 312, 3Rd Floor Khare Town, Dharampeth Aayakar Bhavan, Telangkhedi Road Nagpur - 440010 Civil Lines, Nagpur - 440001 Pan – Aaepy4543Q (Appellant) (Respondent)

Section 132Section 139Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 69ASection 69C

section 139 of the Act for the Atul Manoharrao Yamsanwar year under consideration on 31.10.2013 declaring total income at Rs.2,01,26,970/-. Notice under section 148 of the Act was issued on 23.03.2020. In response to this notice, the assessee filed return under section 148 on 30.11.2020 declaring total

Venkata Lakshmi Padmavathi Uppalapu, Vijayawada vs. ITO, Ward - 2(3), Vijayawada

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

ITA 299/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam09 Jun 2025AY 2013-14

Bench: Shri Veeravalli Durga Rao, Hon’Ble

Section 143(2)Section 147Section 148Section 148ASection 69A

Accordingly, the case of the assessee was reopened under section 147 of the Act with the prior approval of the competent authority. Subsequently, notice under section 148 of the Act was issued on 31.03.2021. In response, the assessee had filed her return of income on 19.08.2021 declaring total income ... merits available on record. 5. On being aggrieved, assessee preferred an appeal before the Tribunal and raised following grounds of appeal: - “]. Notice Under Section 148 Served After 1 April 2021-New Law Applicable The Income Tax Department issued a notice under Section 148 on 30" March 2021,but the same

Arvindbhai Punabhai Patel, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

The appeal of the assessee is partly allowed for statistical purposes

ITA 1998/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad06 Jun 2025AY 2013-14

Bench: Ms.Suchitra R. Kamble

Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

during the financial year 2012-13, which was not reflected in the books of account of the assessee. Accordingly, a notice under section 148 of the Act was issued on 27.05.2016 and served by RPAD. During the course of reassessment proceedings, the Assessing Officer issued several notices under section ... loan and the linked cash deposits, supports the jurisdiction ITA No.1998/Ahd/2024 10 assumed by the AO. The procedural compliance with issue of notice under section 148 and the recording of reasons is not in dispute. We therefore do not find merit in the assessee’s challenge to the validity