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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

Deergold Commercial Pvt. Ltd., North Twenty Four Parganas vs. ITO, Ward - 14(1), Kolkata

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

ITA 2465/KOL/2024[2013-14]Status: DisposedITAT Kolkata23 Apr 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2465/Kol/2024 Assessment Year: 2013-2014

Section 133(6)Section 144Section 147Section 148

addressee cannot be located” but e-mail also delivered. Accordingly, recourse to the proceedings were initiated under section 147 of the Act and notice under section 148 was issued to the assessee asking to file ITR under consideration within thirty days. The assessee filed its ITR on 05.05.2021. Accordingly notices

Moorthy, Salem vs. ACIT, Circle-2, Salem

Appeal of the assessee is allowed

ITA 490/CHNY/2025[2011-12]Status: DisposedITAT Chennai23 Apr 2025AY 2011-12

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr.T.S.Lakshmi VenkatramanFor Respondent: Ms. Anitha, Addl.CIT
Section 143(3)Section 147Section 148

course of reassessment proceedings, can be brought to tax, only, if the escaped income, which caused, in the first instance, the issuance of notice under Section 148 of the Act, is assessed to tax. 22. Explanation 3, to my mind, supports this approach, which emerges upon a plain reading ... other income which has escaped assessment and which, comes to his notice during the course of the proceedings. However, if after issuing a notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped

Assistant Commissioner of Income Tax Ltu Circle 1, Chennai vs. E I D Parry India Limited, Chennai

In the result, appeal filed by the Revenue is dismissed

ITA 3118/CHNY/2024[2011-12]Status: DisposedITAT Chennai23 Apr 2025AY 2011-12

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Sudarmani, AdvocateFor Respondent: Mr.R. Raghupathy, Addl.CIT
Section 143(1)Section 32(1)(iia)

scrutiny and the income returned was accepted, subsequently, the case was re-opened under section 147 of the Act by issuance of notice under section 148 of the Act on 26-3-2014 on the ground that the asset which was purchased and put to use in the previous year

Popatlal Peerchand Shah, Mumbai vs. ITO Ward 19(2)(5) Mumbai, Mumbai

In the result, the grounds of appeal against the validity of reassessment raised by the assessee are allowed

ITA 914/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Apr 2025AY 2012-13

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 144Section 147Section 148Section 250Section 254(1)

income for A.Y. 2012-13 on 20.08.2022 declaring income at Rs. 507240/-. Initially return was accepted. The case was reopened under section 147. Notice under section 148 dated 25.02.2015 was served upon the assessee. Case of assessee was reopened on the basis of information from the investigation wing that assessee ... disallowance of 12.5% of purchases from Shree Sundha Steel Pvt. Ltd. The case of assessee was again reopened under section 147 by issuing notice under section 148 on 30.03.2019. The case of assessee was 2 Popatlal Peerchand Shah reopened on same information that assessee’s beneficiary of purchases shown from

Mukesh Kumar Bhawarlal Jain, Mumbai vs. ITO, WD 23(2)6, Mumbai

In the result, additional ground no

ITA 6745/MUM/2024[2016-17]Status: DisposedITAT Mumbai23 Apr 2025AY 2016-17
Section 144BSection 147Section 148Section 148ASection 151Section 250Section 254(1)Section 69A

approval was not obtained in accordance with provision of section 151(ii) of the Act. Therefore, action initiated in the basis of invalid notice under section 148 is void ab initio. Once, the notice under section 148 is held invalid, subsequent action initiated thereto will not survive. In support ... other hand, the Ld. DR for the revenue submits that in the present case order under section 148A(d) was passed on 27.07.2022. Notice under section 148 dated 27.07.2022 was issued after taking prior approval of competent authority in accordance with the provision of section

Suman Kishore, New Delhi vs. ITO, New Delhi

ITA 1434/DEL/2012[2008-09]Status: DisposedITAT Delhi23 Apr 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2012-13] Sunita Bhardwaj, Vs Acit, 1/2, Taj Apartments, Circle-63(1), R.K.Puram, Sector-12, Delhi Delhi-110022. Pan-Ahfpb1928E Appellant Respondent

Section 1Section 147Section 148Section 250Section 68

impugned order held that where Joint Commissioner recorded satisfaction in mechanical manner and without application of mind to accord sanction for issuing notice under. section 148, reopening of assessment was invalid - Whether Special Leave Petition filed against impugned order was to be dismissed - Held, yes [In favour of assessee] Search ... Commissioner of Income-tax, with the following remarks: "Yes, I am satisfied with the reasons recorded by the Assessing Officer for issuance of notice under section 148 of the Income- tax Act, 1961." (emphasis¹ supplied) 23. The power to sanction reassessment under section 151, is coupled with a duty

Sunil Hanamant Naikwad, Belgaum vs. Income Tax Officer, Ward - 2, Belagavi

The appeal is ALLOWED as above

ITA 220/PAN/2024[2012-13]Status: DisposedITAT Panaji22 Apr 2025AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Sunil Hanmantsa Naikwad 1156, Saraf Galli, Shahapur, Belgaum Pan:Abeph0397N . . . . . . . Appellant V/S Income Tax Officer, Ward-2, Belgaum. . . . . . . . Respondent

For Appellant: Mr JD Kalpavruksha [‘Ld. AR’]For Respondent: Mr Ravindra Hattalli [‘Ld. DR’]
Section 139Section 143(3)Section 147Section 250Section 4

assessment or reassessment of escaped income, and which he intends to taken into accounts, he would be required to issue a fresh notice under Section 148.’ (Emphasis supplied) 10. In the instant case, admittedly the Ld. AO neither made any addition in relation recorded reasons about share transactions undertaken

Om Prakash Sharma, Jaipur vs. Income Tax Officer Ward-7(2), Jaipur

ITA 258/JPR/2025[2009-10]Status: DisposedITAT Jaipur22 Apr 2025AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 258/JPR/2025 निर्धारणवर्ष / AssessmentYears : 2009-10 Shri Om Prakash Sharma 1, N.H. 8, Sanskar Bharti P.G. College Bagru 303 007 (Raj) बनाम Vs. The ITO, Ward-7(2), Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआर सं./PAN/GIR No.: BWKPS 4112 G अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri S.B. Natani, CA राजस्व की ओरसे /Revenue by :Shri Gautam Singh Choudhary, Addl.CIT -DR

For Appellant: Shri S.B. Natani, CAFor Respondent: Shri Gautam Singh Choudhary, Addl.CIT -DR a
Section 143(3)Section 147Section 148Section 151

settled positions of law that total sale of the plot cannot be considered as income. Thus the notice under section 148 was issued determining wrong income. The following case law as quoted in support. i. Commissioner of Income Tax Vs. Williamson Financial Services & Ors (SLP(C) 2275/2007 (Hon’ble Supreme ... order at one place (page 1 of the assessment order), that the return stood filed by the assessee on 12.07.2016 in response to notice under section 148 issued on 31.03.2016, but the learned AO issued show cause notice on 18.11.2016 which has been reproduced on page 2 of the assessment

Sanjivani Shikshan Sansthan, Jaipur vs. ITO WD 6(3), Jaipur

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

ITA 1207/JPR/2024[2016-17]Status: DisposedITAT Jaipur22 Apr 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Rahoan Sogani, C.AFor Respondent: Shri Arvind Kumar, CIT-DR &
Section 144Section 147Section 148Section 151Section 250

assessment within the meaning of Section 147 of the Income-tax act 1961 in the case of the above mentioned assessee with others. Notice under section 148 of the Income Tax Act, 1961 was issued on 31.03.2021. But the assessee did not file income tax return against the notice ... approving authority. 7. Further the Ld. AR contended that the entire process of seeking and granting approval, as well as issuance of notice under Section 148, was completed within a span of less than 12 hours on the same working day, which indicates mechanical approval without due application of mind

Neeraj Gupta, Lakhimpur Kheri vs. Commissioner of Income Tax (Appeals), NFAC, Income Tax Department

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

ITA 643/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 Apr 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 Neeraj Gupta V. The Ito 3(4) Mohammadi Road Lakhimpur Kheri Barkheriya Jat Jang Bahadur Ganj Lakhimpur Kheri Tan/Pan:Btqpg0819P (Appellant) (Respondent) Appellant By: Shrii Pranav Pandey, C.A. Respondent By: Shri Sunil Kumar Rajwanshi, D.R. Date Of Hearing: 03 04 2025 Date Of Pronouncement: 22 04 2025 O R D E R

For Appellant: Shrii Pranav Pandey, C.AFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 115BSection 142(1)Section 147Section 148Section 69A

Commission or Brokerage. The assessee had not filed the return of income for the year under consideration. The Assessing Officer (AO) issued notice under section 148 of the Income Tax Act, 1961 (hereinafter called “the Act’), requiring the assessee to file the return of income for the year under consideration

Csmmu Welfare Society, Lucknow vs. Ld. AO, NFAC, Jurisdictional AO-DCIT(Exemption), Lucknow

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 596/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 Apr 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2017-18 Csmmu Welfare Society V. The Dcit (Exemption) Vc Office, King George Lucknow Medical University Lucknow Tan/Pan:Aaatc6217F (Appellant) (Respondent) Appellant By: Ms. Shweta Mittal, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 21 04 2025 Date Of Pronouncement: 22 04 2025 O R D E R

For Appellant: Ms. Shweta Mittal, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 142(1)Section 147Section 148Section 270A

income for the year under consideration, the case of the assessee-society was reopened under section 147 of the Act by issuing notice under section 148 of the Act. The assessee did not file any return of income in response to notice under section 148 of the Act, but, filed

Pankaj Agarwal, Kanpur vs. Jt.CIT Circle-1(1)(1), Kanpur

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

ITA 267/LKW/2023[2012-13]Status: DisposedITAT Lucknow22 Apr 2025AY 2012-13

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2012-13 Pankaj Agarwal, 7/151, Ratan Vs. The Jt. Commissioner Of Majestic, Opp. Sony World, Income Tax, Circle 1(1)(1), Swaroop Nagar, Kanpur-208002 Kanpur-208001 Pan:Abjfs4912R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Sanjeev Krishna Sharma Sr Dr & Sh Sunil Kumar Rajwanshi, Addl Cit Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 22.04.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 On 21.08.2023. The Grounds Of Appeal Are As Under:- “1. Because The Cit (A) Has The Erred On Facts & In Law In Upholding The Disallowance Of Rs.2,47,02,865/- On Account Of Loss In Trading In Derivatives Business Treating The Same As Capital Loss, As Against Assessee'S Claim Of Business Loss, To Be Set Off Against Other Business Income, Which Order Is Contrary To Facts, Bad In Law, The Disallowance Made By The Ao & Upheld Be Deleted. 2. Because On A Proper Consideration Of The Facts & Circumstances Of The Case & Also On The Interpretation Of The Provisions Of Sec 43(5), It Would Be Found The Loss Of Rs.2,47,02,865/- On Account Of Trading In Derivative Is Neither A Speculative Loss Nor A Capital Loss, The Same Should Ought To Be Set Off Against Other Business Income, The Cit (A) Has Erred, In Treating The Same As Short Term Capital Loss.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Sanjeev Krishna Sharma Sr DR & Sh
Section 14ASection 250Section 43(5)Section 72

adverse inference was taken 16 A.Y. 2012-13 Pankaj Agarwal on this point and that in the assessment year 2015-16, where notice under section 148 was issued, the notice was dropped without making any such addition. Therefore, the stand of the Ld AO in this assessment year would also

DCIT, Central Circle-1(2), Ahmedabad, Aaykar Bhawan Ashram Road vs. Sureshkumar Periwal (PAN Aftpp6547D, Ahemdabad

In the result, both the appeals of the Revenue are dismissed

ITA 1116/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad22 Apr 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kambleit(Ss)A No. 153/Ahd/2023 (Assessment Year: 2017-18) Sureshkumar Periwal Deputy Commissioner Of Vs. Prop. Of M/S. Shyam Bullion, Income-Tax, 113, First Floor, National Central Circle-1(2), Plaza, Opp. Lal Bungalows, Ahmedabad Cg Road, Ahmedabad [Pan : Aftpp 6547 D] (Appellant) .. (Respondent) Sureshkumar Periwal Deputy Commissioner Of Vs. Prop. Of M/S. Shyam Bullion, Income-Tax, 113, First Floor, National Central Circle-1(2), Plaza, Opp. Lal Bungalows, Ahmedabad Cg Road, Ahmedabad [Pan : Aftpp 6547 D] (Appellant) .. (Respondent) Appellant By: Shri V. Nandakumar, Cit-Dr & Shri Kavan Limbasiya, Sr. Dr Respondent By : Shri Biren Shah, Ar Date Of Hearing 12.03.2025 Date Of Pronouncement 22.04.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri V. Nandakumar, CIT-DR &For Respondent: Shri Biren Shah, AR
Section 132Section 133ASection 143(3)Section 147Section 148Section 68

basis of information available on insight portal the Assessing Officer reopened the case of the assessee and a notice under section 148 of the Act served to the assessee as on 09.03.2021. The Assessing Officer passed an assessment order under u/s 143(3) r.w.s. 147 of Act by determining

Vasant Shivram Madhavi, Panvel vs. ITO Ward - 5, Panvel

ITA 1716/PUN/2024[AY 2015-16]Status: DisposedITAT Pune22 Apr 2025

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2015-16

For Appellant: S/Shri Bhupendra Shah and Babulal JainFor Respondent: Shri Ajay Kumar Keshari - CIT
Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Highland Tardelink (P) Ltd., Kolkata vs. A.O, NFAC.Delhi., Delhi

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

ITA 1104/KOL/2023[2009-2010]Status: DisposedITAT Kolkata22 Apr 2025AY 2009-2010

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 147Section 148Section 151Section 263

thus: “9. It is undisputed position before us that in terms of Section 151(2) of the Act, the sanctioning/ permission to issue notice under Section 148 of the Act has to be issued by the Additional Commissioner of Income Tax. We find that the Assessing Officer had not sought ... dated 25th March, 2011 to re-open the Assessment. Further, it is the Commissioner of Income Tax who directed the issuance of the notice under Section 148 of the Act to the Assessing Officer. Thus, it is very clear that the final sanction/ approval was that of the Commissioner

Mr. Viren Rohitkumar Shah, Mumbai vs. ITO Ward 32(2)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 90/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Apr 2025AY 2016-17

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalmr. Viren Rohitkumar Shah, 02/009 Om Heera Pana Mall, Oshiwara, Andheri (W), Mumbai - 400102 ............... Appellant Pan : Aaqps2809B V/S

For Appellant: Shri Hitesh JainFor Respondent: Ms. Kavitha Kaushik, Sr.DR
Section 147Section 148Section 148ASection 151Section 234BSection 250Section 271(1)(c)Section 69

diamond/gold jewellery and the assessee being one such person who has made payment for purchase of jewellery during the year, the AO issued notice under section 148 of the Act on 23/06/2021. 8. Subsequently, in view of the decision of the Hon’ble Supreme Court in Union of India ... order under section 148A(d) of the Act was passed on 31/07/2022 declaring that it is a fit 5 case for issuance of notice under section 148 of the Act. Thereafter, on 31/07/2022, notice under section 148 of the Act was issued by the Jurisdictional Assessing Officer. As the assessee

ITO Ward 3(4), Thane vs. Sunil Kumar Bagaria, Thane

In the result, the appeal by the Revenue is dismissed

ITA 7/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Apr 2025AY 2014-15

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalito, Ward-3(4), Room No.9, B-Wing, 6Th Floor, Ashar It Park, Wagle Industrial Estate, ............... Appellant Thane West - 400604

For Appellant: Shri Neelkanth KhandelwalFor Respondent: Shri Vijaykumar G. Subramanyam, Sr.DR
Section 144BSection 147Section 148Section 250Section 250(4)

capital gains/short-term capital loss to beneficiaries, and the assessee is one such beneficiary, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 31/03/2021. In response, the assessee 3 filed a letter submitting that the return of income filed

Income Tax Officer Ward 25 (3)(1), Mumbai, Kautliya Bhavan, Bandra Kurla Complex vs. Nikunj Ambalal Patel (HUF), Mumbai

In the result, the appeal of the revenue is dismissed

ITA 4303/MUM/2024[2017-18]Status: DisposedITAT Mumbai22 Apr 2025AY 2017-18

Bench: Shri Sandeep Gosain & Smt. Renu Jauhriआयकर अपील सं./Ita No. 4303/Mum/2024 (निर्धारण वर्ा / Assessment Year :2017-18)

For Appellant: Shri Satyaprakash SinghFor Respondent: Ms. Rampriya Raghavan
Section 143(1)(a)Section 147Section 148Section 250Section 69C

also raised the following grounds of appeal: “Ground No.1: The Learned A.O. erred in making addition on grounds not forming part of the notice under section 148 of the Income-tax Act, 1961 read with section 147, even though he did not make any addition on the reason in respect ... which he had reason to believe that income has escaped assessment and which formed the basis of a notice under section 148. The Learned A.O. erred in not considering that it is not open to the Assessing Officer to assess or reassess independently any other income, which does not form

Marie Products Private Limited, Jaipur vs. Assistant Commissioner of Income Tax, Circle 7, Jaipur

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

ITA 771/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Apr 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Ajay Malik, CIT
Section 14Section 142(1)Section 143(3)

Nath Suresh Chand Ram Naresh Vs. CIT (2006) 280 ITR 396: The Allahabad High Court held that the issue of notice under Section 148 of the Income Tax Act is a condition precedent to the validity of any assessment order to be passed under section

Parkash Thakur, Chandigarh vs. Income Tax Officer, Chandigarh

In the result, appeal is allowed for statistical

ITA 332/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh21 Apr 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Yashpreet Singh, CAFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 148Section 250

assessee's transactions during the year have been reflected in the bank accounts as well as sale/purchase of properties. The AO has issued notice under Section 148 but it was not replied by the assessee. Ultimately, he has passed the ex- parte assessment order. 4. Dissatisfied with the above, assessee