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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

M/S Gurmat Parchar Sabha (Regd.), Chandigarh vs. Nwr-W-(41)(91), Chandigarh

In the result, the appeal is allowed

ITA 1050/CHANDI/2024[2019-2020]Status: DisposedITAT Chandigarh21 Apr 2025AY 2019-2020

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Maninder Arora, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR
Section 144BSection 148Section 148ASection 151Section 151A

Court in the case of Jatinder Bhangu read as under : 14. The respondent during the course of arguments vehemently and vigorously pleaded that notice under Section 148 can be issued by Jurisdictional Assessing Officer. In support of his contention, they heavily relied upon office memorandum dated 2').02.2023 and letter ... perusal of Section 151 A. it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable to notice

Shrikant Chandrakant Lokhande, Latur vs. ITO, Ward-1, Latur

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

ITA 2696/PUN/2024[2015-16]Status: DisposedITAT Pune21 Apr 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2696/Pun/2024 Assessment Year : 2015-16

For Appellant: Shri Ganesh Vijaykumar PawarFor Respondent: Shri Kumar Manish Sinha
Section 115BSection 139Section 142(1)Section 147Section 148Section 156Section 208Section 234B(1)Section 249Section 249(4)

Section 148: Issue: Proceedings of reassessment barred by time: That the CIT(A) erred in law in not appreciating the fact that notice under section 148 of the Act was issued based on some information flagged as per Risk Management Strategy formulated by the CBDT in NMS module of insight ... amount which was not properly uploaded and there was mistake in uploading the said information. He erred in not considering the fact that Notice under section 148 of the Act was issued on 10.04.2022 based on some flagged information as per CBDT risk management matrics after a period of three

Somnath Konduru, United States vs. I.T.O (Int Taxn)-1, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 179/HYD/2024[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA K C DevdasFor Respondent: Shri B Bala Krishna, CIT-DR
Section 144Section 144CSection 144C(1)Section 144C(13)Section 144C(2)Section 144C(5)Section 148

value was at Rs.58,48,000/-. The Assessing Officer has recorded reasons and after taking approval from the prescribed component authorities, notice under section 148 of the Act dated 28.03.2021 was issued and served on the assessee. The assessee vide his reply dated 06.05.2021 submitted that ... assessee 6 ITA.No.179/Hyd./2024 submitted that, the initiation of re-assessment proceedings under section 147 of the Act by issuing notice under section 148 dated 21.03.2021 is illegal, void abinitio and liable to be quashed, because the Assessing Officer reopened the assessment on wrong assumption of facts that

Navin Kumar Chaudhary, Delhi vs. ITO, Delhi

Appeal is allowed for statistical purposes

ITA 118/DEL/2025[2013-14]Status: DisposedITAT Delhi21 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara

For Appellant: NoneFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 143(3)Section 147Section 148Section 250(6)

after disallowing expenditure being personal nature under the head Car Maintenance, Telephone & Travelling Expenses to the tune of Rs 41,790/-. Later on, notice under section 148 of the Act was issued for reopening of the case by recording reason u/s 147 and 2 taking permission of the Pr. Commissioner

Sri. Vinayaka Education Institution R, Mandya vs. ITO, Exemptions Ward, Mysore

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

ITA 35/BANG/2025[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2017-18

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Subramanian S, JCIT (DR)
Section 10Section 139Section 234ASection 69A

assessee. Therefore, the AO forms the reason to believe that income chargeable to tax has been escaped and reopened the assessment by issuing notice under section 148 of the Act, dated 29-03-2021. 5. The AO found that the assessee was provided several opportunities to explain the sources

Chandrakala Narala, Bengaluru vs. Income Tax Officer, Ward-5(3)(3), Bangalore

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

ITA 2575/BANG/2024[2016-17]Status: DisposedITAT Bangalore21 Apr 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17

For Appellant: Shri. Pranit Tanna, CAFor Respondent: Smt. Neha Sahay, JCIT(DR)(ITAT), Bangalore
Section 144Section 147Section 148Section 234BSection 249(4)(b)Section 250Section 271(1)(b)Section 282ASection 69A

filed her return of income. As per the information received, the case was reopened under section 147/148 of the Act and notice under section 148 of the Act was issued to the assessee and the assessee was allowed time to file return of income within 30 days from the receipt

Vividhodhesha Prathamika Gramina Krushi Sahakara Sangha Ni Gejjalagere, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result appeal of the assessee is partly allowed

ITA 2071/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmedassessment Year: 2018-19

For Appellant: Shri Tarun Kothari, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 147Section 148Section 151Section 254Section 80P

deposits and cash withdrawal by the assessee society for Rs. 2,12,56,200/- and Rs. 1,54,13,000/- respectively. Accordingly, a notice under section 148 of the Act was issued for income escaping assessment as on 1st April 2022. The assessee in response to the notice issued under ... showcasing the assessee to explain why the assessment should not be reopened by issuing notice under section 148 r.w.s. 147 of the Act. The AO in the notice issued under section 148A(b) required the assessee to make a reply on or before 25th March 2022. The assessee society before

Income Tax Officer -5(3)(1), Mumbai vs. M/S. Shree Sundha Steels Private Limited, Mumbai

In the result, the appeal filed by the revenue bearing ITA 1756/Mum/2025

ITA 1756/MUM/2025[2008]Status: HeardITAT Mumbai21 Apr 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeincome-Tax Officer -5(3)(1), Vs M/S Shree Sundha Steels Private Mumbai, Limited, 5Th Room No.526, Floor, 15/16, D-Wing,Groundfloor, Gora Aayakar Bhawan, Mumbai-400 Gandhi Palace, 122, Khetwadi Back 020 Road, Khetwadi, Mumbai-400 004 Pan: Aaics1816M Appellant Respondent

For Appellant: Shri Bharat Kumar, CAFor Respondent: Shri Asif Karmali (SR. DR.)
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 250

Subsequently, the case was selected for scrutiny, and the assessment was completed under section 143(3) of the Act. Thereafter, notice under section 148 of the Act was issued based on information received from the Investigation Wing of the Income Tax Department regarding alleged bogus purchase transactions undertaken

M/S. Kishor D Naik (HUF), Mumbai vs. ACIT, Central Circle -2, Thane

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

ITA 5587/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Apr 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 139(1)Section 143(3)Section 153CSection 292C

Officer's jurisdiction to undertake proceedings has to be tested/examined only on the basis of reasons recorded at the time of issuing a notice under Section 148 of the Act seeking to reopen an assessment. These reasons cannot be improved upon and/or supplemented much less substituted by affidavit and/or oral

Jignesh Suresh Shah, Mumbai vs. Income Tax Department Income Tax Officer Ward, 1, Thane

ITA 5151/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 Apr 2025AY 2010-11

Bench: Shri Narender Kumar Choudhry, Jm & Ms Padmavathy S, Am

For Appellant: Shri Krishna Kumar, Sr. DR
Section 148Section 271Section 271B

much more than what is declared by the assessee in the return of income. Accordingly the AO reopened the assessment by issuing a notice under section 148 of the Income Tax Act, 1961 (the Act). The assessee filed the return of income in response to notice under section 148

DCIT, Circle 42(1)(1), Income Tax Department vs. Ghanshyam Rasiklal Shah, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 4707/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Apr 2025AY 2012-13

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeedcit, Circle 42(1)(1), Mumbai Vs Ghanshyam Rasiklal Shah Room 732, 7Th Floor, B-1408, Shankar Park, Agrawal Kautilya Bhavan, Bkc, Bandra Residency, Shankar Lane, Kandivali East, Mumbai-400 051 West, Mumbai-400 067 Pan: Aafps1306Q Appellant Respondent

For Appellant: Shri Subodh Ratnaparkhi - CAFor Respondent: Shri BhangepatilPushkaraj Ramesh
Section 132Section 143(3)Section 147Section 148Section 153CSection 250Section 69A

account of alleged escaped income cannot be sustained. The Ld. AO reopened the assessment under Section 147 of the Act,by issuing a notice under Section 148 dated 30.03.2019. From the copy of the recorded reasons for reopening, it is evident that the Ld. AO reopened the assessment for alleged ... action under Section 147 in such circumstances would render Section 153C redundant. Accordingly, the assumption of jurisdiction under Section 147 by issuance of notice under Section 148 dated 30.03.2019 is invalid, and the resulting assessment is liable to be quashed. The assessee, under Ground No. 3, has challenged this erroneous

Nandan Singh, Pithoragarh vs. CIT(A), National Faceless Assessment Centre, New Delhi

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

ITA 185/DDN/2024[2019-20]Status: DisposedITAT Dehradun17 Apr 2025AY 2019-20

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singhassessment Year: 2019-20 Nandan Singh, Vs. Cit(Appeals)/National Payya Pauri, Faceless Appeal Pithoragarh Cemtre(Nfac) Assessment Uttarakhand Centre, Pan No. Bfaps4805M Delhi (Appellant) (Respondent)

For Appellant: Shri SK Ahuja, ARFor Respondent: Shri Amarpal Singh Sr. DR
Section 142Section 142(1)Section 143(2)Section 144B(1)Section 147Section 148

No.30447713114. During relevant assessment year 2019-20, assessee had not filed return of income. The case of assessee was reopened after recording reasons. Notice under Section 148 of the Act was issued. In pursuance to notice under Section 148, return of income was filed on 19.05.2023 by the assessee. Notices ... extended. However, retiral benefits were released to the assessee and same were later on recovered by the Indian Army. In response to notice under Section 148 of the Act, assessee had filed return of income as per Form 16 attached with statement as Annexure “A”. Amount credited on various dates

Kunwar Toseen, Kotdwar Distt. Pauri Garhwal vs. Income Tax Officer, Kotdwar

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

ITA 179/DDN/2024[2018-19]Status: DisposedITAT Dehradun17 Apr 2025AY 2018-19

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

For Appellant: N o n eFor Respondent: Shri A.S. Rana, Sr. DR
Section 144BSection 147Section 148Section 148ASection 271A

more accounts of cash deposits and assessee did not file return of income. After recording reasons, the case was reopened by issue of notice under Section 148 of the Act on 25.03.2023 with prior approval of the DCIT, Dehradun. Despite intimation letter dated 17.08.2022, multiple notices under Sections

Kunwar Toseen, Kotdwar Distt. Pauri Garhwal vs. Income Tax Officer, Kotdwar

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

ITA 178/DDN/2024[2018-19]Status: DisposedITAT Dehradun17 Apr 2025AY 2018-19

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh

For Appellant: N o n eFor Respondent: Shri A.S. Rana, Sr. DR
Section 144BSection 147Section 148Section 148ASection 271A

more accounts of cash deposits and assessee did not file return of income. After recording reasons, the case was reopened by issue of notice under Section 148 of the Act on 25.03.2023 with prior approval of the DCIT, Dehradun. Despite intimation letter dated 17.08.2022, multiple notices under Sections

Sushma Sharma, Jaipur vs. ITO, Jaipur

ITA 1328/JPR/2024[2009-10]Status: DisposedITAT Jaipur17 Apr 2025AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Arbind SharmaFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 142(1)Section 144Section 148Section 156Section 271Section 271(1)(b)Section 271(1)(c)

notice were issued by the A.O at this address. The Quashed assessment order of A.O dated 7-10-2016 has mentioned that the notice under section 148 was issued on dated 15-3-16 through speed 3 Sushma Sharma vs. ITO post AD but returned back as unserved from postal

Pukhraj, Bharatpur vs. Income Tax Officer, WD-1, Bharatpur

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

ITA 1114/JPR/2024[2011-12]Status: DisposedITAT Jaipur17 Apr 2025AY 2011-12

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalpukhraj, C/O. Virendra Singh Gothiya, Atal Bandh Gate, Dhau Pyasa, Bharatpur 321 001 Pan No.: Birpp 6009G ...... Appellant Vs. Income Tax Officer Ward-1, Bharatpur ...... Respondent

For Appellant: Mr. Sankalp Pitaliya, CA, Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, JCIT- Ld. DR
Section 148Section 250

Court of India 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" So, the reopening of assessment with mechanical approval of PCIT, without application of mind is invalid and order

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR
Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

Relaxation Act, 2020, the Central Government issued following notifications inter-alia extending the time lines prescribed under Section 149 for issuance of reassessment notices under Section 148 of the Income Tax act, 1961: The explanation to the notifications dated 31 March, 2021 and 27th April, 2021 issued under section ... respect of each of the concerned assessees: Thereafter after following the procedure as required under section 148A may issue notice under section 148 (as substituted). It was also held that 6 all defenses which may be available to the assesses including those available under section

Assistant Commissioner of Income Tax, Circle-25(1), Delhi vs. Vikas Strips Private Limited, Delhi

In the result, the appeal of the revenue is dismissed and Rule 27

ITA 2811/DEL/2024[2008-09]Status: DisposedITAT Delhi17 Apr 2025AY 2008-09

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaacit, Vs. Vikas Strips Pvt. Ltd, Circle-25(1), 10, Ashoka Park, Rohtak Delhi Road, Delhi (Appellant) (Respondent) Pan: Aabcv7134J

For Appellant: Shri Sandeep Goel, AdvFor Respondent: Shri Amit Katoch, Sr. DR
Section 143(3)Section 148Section 151Section 68

declaring total income of Rs. 8,15,360/-. The assessment was sought to be reopened vide issuance of notice under section 148 of the Act on 30-3-2015. This notice was issued after obtaining approval under section 151 of the Act from the ld JCIT, Range 26, New Delhi ... stating that the return originally filed by it on 7-8-2008 may be treated as a return in response to notice under section 148 of the Act. Thereafter, the assessee sought the copy of reasons recorded for reopening the assessment, which were duly furnished to the assessee

Alagarsamy, Dindigul vs. DCIT, Ward-1, Dindigul

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

ITA 315/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.: 315/Chny/2025 िनधा"रणवष" / Assessment Year: 2017-18 Alagarsamy, Vs. The Deputy Commissioner Of 1, Anumantharayan Kottai, Income Tax, Dindigul – 624 001, Ward -1, Tamil Nadu. Dindigul. [Pan: Biqpa-6564-C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" कीओर से/ Appellant By : Shri A.G. Sathyanarayana Advocate ""थ"की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing 20.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short] Dated 22.06.2024 Pertains To The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 153 Days. The Assessee Filed A Petition For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Assessee Are Bonafide, Which Really Prevented In :-2-:

For Appellant: Shri A.G. Sathyanarayana AdvocateFor Respondent: Shri A. Sasi Kumar, CIT
Section 142(1)Section 144Section 147rSection 148Section 250Section 69A

different account maintained by him in the Catholic Syrian Bank Ltd. other than the current account in banks. The Assessing Officer issued notice under section 148 of the Act requiring the assessee to file income tax return, for which, there was no response from the assessee. Thereafter, the Assessing Officer

Revathikumar Sudha, Chennai vs. ACIT, Ncw-19(1), Chennai

In the result the appeals of the assessee in ITA No

ITA 305/CHNY/2025[2015-16]Status: DisposedITAT Chennai17 Apr 2025AY 2015-16

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकर अपीलसं./Ita Nos.: 304 & 305/Chny/2025 िनधा"रण वष" / Assessment Year: 2015-16 Revathikumar Sudha, Vs. The Assistant Commissioner Of 29, 3Rd Main Road, Thilaiganga Income Tax, Nagar, Chennai 600 061. Non Corporate Ward –19(1), Chennai. [Pan: Aztps-8926-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short] Both Dated 12.12.2024 Pertains To The Assessment Year 2015-16 Towards Quantum Addition As Well As Penalty Levied Under Section 271(1)(C) Of The Act.

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri A. Sasi Kumar, CIT
Section 142(1)Section 143(3)Section 144Section 147Section 148Section 194ISection 250Section 271(1)(c)Section 56

purchase consideration of immovable property chargeable to tax has escaped assessment, proceedings under section 147 of the Act was initiated by issuing notice under section 148 of the Act. However, the assessee did :-3-: ITA. Nos: 304 & 305/Chny/2025 not file his return of income against the notice under section 148