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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

Mark Foods, Mumbai vs. Income Tax Officer-28(2)(1), Mumbai

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

ITA 4102/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 Apr 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Girish Agrawal

For Appellant: Shri Shashank Mehta, CAFor Respondent: Shri R. R. Makwana, Addl. CIT
Section 143Section 147Section 148Section 151ASection 153CSection 68

case and in law, the Learned CIT(A) has erred in upholding the action of the Ld. Jurisdictional Assessing Officer of issuance of notice under section 148 dated 22.07.2022 which is barred by limitation and in violation of law laid down in the case of Hexaware Technologies Limited vs. ACIT ... case and in law, the Learned CIT(A) has erred in upholding the action of the Ld. Jurisdictional Assessing Officer of issuance of notice under section 148 in violation of provisions contained in section 151A of the Act and in violation of law laid down in the case of Hexaware

Inderpal Singh Chhabra, Rourkela vs. ACIT, Rourkela

In the result, appeal of the assessee is allowed

ITA 450/CTK/2024[AY 2018-19]Status: DisposedITAT Cuttack08 Apr 2025

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.450/Ctk/2024 (नििाारण वर्ा / Assessment Year : 2018-2019) Inderpal Singh Chhabra Vs Acit, Circle Rourkela Prop: Essar Enterprises Daily Market, C/O Crazy Cool, Main Rd, Po/Ps : Rourkela, Dist : Sundargarh Pan No. :Ajlpc 6337 J (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri P.K.Mishra & Shri Baidyanath Behera, Advocates राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/04/2025 घोषणा की तारीख/Date Of Pronouncement : 08/04/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Nfac, Delhi Dated 04.09.2024 In Din & Order No.Itba/Nfac/S/250/2024-25/1068345718(1)), For The Assessment Year 2018-19. 2. Shri P.K.Mishra, Advocate Appeared On Behalf Of The Assessee. Shri Sanjay Kumar, Ld Cit Dr Represented On Behalf Of The Revenue. 3. The Assessee Is Engaged In The Transportation Of Coal & Trading In Coals. It Was Submitted By Ld Ar That The Original Return Filed By The Assessee Came To Be Processed U/S.143(3) Of The Act By The Nfac & The Assessment Came To Be Completed On 10.02.2021 Accepting The Returned Income. Ld Ar Drew Our Attention To Page 3 Of The Paper Book

For Appellant: Shri P.K.Mishra & Shri BaidyanathFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 142(1)Section 143(3)Section 206CSection 43B

would be worthwhile to extract the provisions of section 148A(d) which reads as under:- [Conducting inquiry, providing opportunity before issue of notice under section 148. 148A. The Assessing Officer shall, before issuing any notice under section 148,— (a) xxxxxx (b) provide an opportunity of being heard to the assessee ... 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

Sahab Kur, Kurukshetra vs. ITO Ward No. III, Ward No. III

In the result, appeal of the Assessee is allowed

ITA 672/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh08 Apr 2025AY 2012-13

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashutosh Gupta, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 144Section 147Section 148Section 153Section 2(24)Section 69A

under Section 147 of Income Tax Act, 1961 after the expiry of 9 months from the end of the financial year in which notice under Section 148 was served. 3. Because, the Learned CIT (Appeals) has not made any observation on the merits of the case, and the grounds raised ... Kurukshetra, during the Financial Year (FY) 2011-12 (Assessment Year (AY) 2012-13). The Assessing Officer (AO), upon detecting these deposits, issued statutory notices under Sections 148 and 142(1) of the Income Tax Act, 1961, seeking explanations for the source of the cash. The assessee failed to respond

Puneet Saggar, Ludhiana, Punjab vs. Income Tax Officer, Ward 6(1), Ludhiana, Punjab

In the result, appeal of the assessee is allowed

ITA 505/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh08 Apr 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri B.M.Monga, Advocate and Shri Rohit Kaura, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 148Section 148A

specific finding. In Ground No. 3 assessee has challenged re-opening of assessment by A.Y. 2015-16 2 issuance of a notice under Section 148 read with Section 148A(d) of the Income Tax Act. 3. The ld. Counsel for the assessee, at the very outset submitted that issue ... income electronically on 30.09.2015 declaring total income at Rs.9,73,710/-. The ld. AO sought to reopen the assessment by issuance of a notice under Section 148 of the Income Tax Act on 28.07.2022. The ld. Counsel for the assessee has pointed out that Hon'ble Supreme Court

Mr. Ramchandra Gopalkrishnan, Mumbai vs. Asst.CIT 2(3), Mumbai

In the result, Ground No. 3 of the

ITA 548/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Apr 2025AY 2012-13

Bench: Shri Pawan Singhshri Girish Agrawal(Physical Hearing) बनाम Mr. Gopalkrishnan Ramchandran Acit, Central Circle – 2(3) 901/902, Rustom Villa, Parsi Pratishtha Bhavan, Vs Colony, Dadar(E), Mumbai - 400014 Mumbai-400020 Pan No. Aaepg3691H अपीलाथ"/Appellant ""थ" /Respondent िनधा"रतीकीओरसे /Assessee By Shri Nishit Gandhi / Ms. Aadnya Bhandari, Ar राज"कीओरसे /Revenue By Shri Rajesh Meshram, Sr. Dr सुनवाईकीतारीख/Date Of Hearing 25.03.2025 उद्घोषणाकीतारीख/Date Of 08.04.2025 Pronouncement

Section 133ASection 143Section 143(2)Section 147Section 148Section 254(1)

above grounds at the time of hearing. 2. Brief facts of the case are that assessee was reopened under section 147. Notice under section 148 dated 27.03.2019 was served upon the assessee 2 Mr. Ramchandran Gopalkrishnan after recording the reasons. The case of assessee was reopened on the basis ... within meaning of clause (c) of Explanation 2 of section 147. On the basis of such reasons recorded, the assessing officer issued notice under section 148. In response to notice under section 148, the assessee filed his return of income on 03.05.2019 declaring income of Rs. 37.89 lacs. The assessing

Income Tax Officer 23 3 6, Piramal Chambers vs. Rahul Hariprasad Tibrewal, Mumbai

ITA 430/MUM/2025[2017-18]Status: DisposedITAT Mumbai08 Apr 2025AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: Shri Dharmesh ShahFor Respondent: Shri R. R. Makwana
Section 144BSection 147Section 148Section 148ASection 250

Assessment Year 2017-2018. The Assessee has filed cross objection. 2. The relevant facts in brief are that notice under Section 148 of the Act (old regime) was issued to the Assessee for the Assessment Year 2017-2018 on 21/06/2021 (i.e., before the expiry of 4 years from ... 30/07/2022, and the same was followed by issuance of notice dated 30/07/2022, under Section 148 of the Act (new regime). Thus, the notice under Section 148 of the Act (new regime) was issued after the expiry of 3 years from the end of the relevant assessment year

Swati Energy & Projects (P) Ltd., Mumbai vs. DCIT 14(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 310/MUM/2025[2010-11]Status: DisposedITAT Mumbai08 Apr 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri Pradip N. Kapasi, A/RFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 143(3)Section 148Section 151Section 234D

case for issue of Notice u/s.148 of the Income Tax Act, 1961. Approval may kindly be accorded for issue of notice under section 148 of the I.T. Act, 1961.” I.T.A. No. 310/Mum/2025 4 4.1.1. Since the notice itself is dated 31/03/2017, it can be seen that the re-opening

Uniquestar Gems (India) Pvt. Ltd., Mumbai vs. The ITO, Ward 13(2)(1), Mumbai.

In the result the appeal filed by the assessee for A

ITA 1036/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Apr 2025AY 2013-14

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 148Section 148ASection 68

TOLA apply "notwithstanding anything contained in the specified Act." Section 3(1), therefore, overrides the time limits for issuing a notice under section 148 read with Section 149 of the Income-tax Act; d. TOLA does not extend the life of the old regime. It merely provides a relaxation ... Revenue between 1 April 2021 and 30 June 2021 as show-cause notices in terms of Section 148A(b). Thereafter, the Revenue issued notices under section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground

Uniquestar Gems (India) Pvt. Ltd., Mumbai vs. The ITO, Ward 13(2)(1), Mumbai.

In the result the appeal filed by the assessee for A

ITA 1035/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Apr 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 148Section 148ASection 68

TOLA apply "notwithstanding anything contained in the specified Act." Section 3(1), therefore, overrides the time limits for issuing a notice under section 148 read with Section 149 of the Income-tax Act; d. TOLA does not extend the life of the old regime. It merely provides a relaxation ... Revenue between 1 April 2021 and 30 June 2021 as show-cause notices in terms of Section 148A(b). Thereafter, the Revenue issued notices under section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground

Subhash Chander Gupta, H.No. 16528 Vishnu Colony, Raliway Road, Kurukshetra, Haryana vs. Joint Commissioner of Income Tax, Kurukshetra

In the result, both appeals of the assessee are

ITA 768/CHANDI/2024[2011-2012]Status: DisposedITAT Chandigarh07 Apr 2025AY 2011-2012

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Abhinav Gupta, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 148Section 153C

assessee Shri Subhash Gupta, ITA No.765&768/CHD/2024 A.Y.2011-12 10 therefore, he harboured the belief that income has escaped assessment and a notice under Section 148 deserves to be issued. The ld. Counsel for the assessee drew our attention towards Section 153C of the Income Tax Act after its amendment ... held that this amendment will be applicable with retrospective effect. On the strength of this judgement, he submitted that instead of a notice under Section 148, the ld. AO ought to have followed the procedure contemplated in Section 153C which is a mandatory one since he failed to follow this

Subhash Chander Gupta, H.No. 1652 8 Vishnu Colony, Railway Road, Kurukshetra, Haryana vs. ITO Ward-3, Kurukshetra, Haryana

In the result, both appeals of the assessee are

ITA 765/CHANDI/2024[2011-2012]Status: DisposedITAT Chandigarh07 Apr 2025AY 2011-2012

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Abhinav Gupta, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 148Section 153C

assessee Shri Subhash Gupta, ITA No.765&768/CHD/2024 A.Y.2011-12 10 therefore, he harboured the belief that income has escaped assessment and a notice under Section 148 deserves to be issued. The ld. Counsel for the assessee drew our attention towards Section 153C of the Income Tax Act after its amendment ... held that this amendment will be applicable with retrospective effect. On the strength of this judgement, he submitted that instead of a notice under Section 148, the ld. AO ought to have followed the procedure contemplated in Section 153C which is a mandatory one since he failed to follow this

Dharamvir Singh, Village Thamber vs. ITO Ward 1, Ambala

In the result, the impugned order and the proceedings are unsustainable in law

ITA 66/CHANDI/2024[2015-2016]Status: DisposedITAT Chandigarh07 Apr 2025AY 2015-2016

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ajay Jain, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 147Section 148Section 148ASection 149Section 151

escaped assessment and therefore entire proceeding is bad in law and serves to be quashed . 2. That the Ao has wrongly issued notice under section 148 of Income Tax which is barred by time limitation prescribed under section 149 of income Tax Act . 3. That the AO has not served ... escaped assessment and therefore entire proceeding is bad in law and serves to be quashed. 2. That the AO has wrongly issued notice under section 148 of Income Tax which is barred by time limitation prescribed under section 149 of income Tax Act 3. That the AO has not served

Kuldeep Kaur, Vill-Deshu Majra, Mohali vs. Income Tax Officer, Mohali

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

ITA 5/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh07 Apr 2025AY 2011-12

Bench: The Hearing Of Appeal With The Permission Of The Honourable Income Tax Appellate Tribunal, Chandigarh.

For Appellant: NoneFor Respondent: Shri Vivek Vardhan, Addl. CIT
Section 142(1)Section 144Section 147Section 148Section 271(1)(c)

with prior approval from the Principal CIT- 2, Chandigarh. The reassessment was started after recording reasons for reopening of the case, and a notice under Section 148 of the Income Tax Act, 1961, was issued on 28.03.2018. 3.1 In response to the notice dated 28.03.2018 issued under Section 148

Sushil Rajbanshi Gupta, Bhandup West Mumbai vs. Ward 41(4)(4), Kautilya Bhavan Bkc Mumbai

ITA 1121/MUM/2025[2017-18]Status: DisposedITAT Mumbai07 Apr 2025AY 2017-18

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dharan GandhiFor Respondent: Shri Gotimukul Santosh Kumar
Section 144Section 144BSection 147Section 148Section 250Section 69

order under section 147 is therefore illegal and without jurisdiction. 2. On the facts and circumstances of the case and in law, the notice under section 148 is bad in law and without jurisdiction as the jurisdictional conditions of section 147 to 151 have not been complied with

DCIT-CC(5), Mumbai vs. Larsen & Toubro Limited, Mumbai

In the result, for A.Y. 2015-16, appeal by the revenue is dismissed and cross objection by the assessee is allowed

ITA 5745/MUM/2024[2014-15]Status: DisposedITAT Mumbai07 Apr 2025AY 2014-15

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri J.D. Mistry, Sr. Advocate and Shri Ronak Joshi, CAFor Respondent: Dr. K.R. Subhash, CIT DR and Shri Ram Krishn Kedia, Sr. DR
Section 147Section 148

issued at any time in a case for the relevant Assessment Year beginning on or before 1st day of April, 2021, if a notice under section 148 or section 153A or section 153C could not have been issued at that time on account of being beyond the time limit specified ... notices. b. Interplay of Ashish Agarwal with TOLA 108. The Income-tax Act read with TOLA extended the time limit for issuing reassessment notices under section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June 2021. All the reassessment notices under challenge

DCIT-CC- 5(4), Mumbai vs. Larsen & Toubro Limited, Mumbai

In the result, for A.Y. 2015-16, appeal by the revenue is dismissed and cross objection by the assessee is allowed

ITA 5743/MUM/2024[2015-16]Status: DisposedITAT Mumbai07 Apr 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri J.D. Mistry, Sr. Advocate and Shri Ronak Joshi, CAFor Respondent: Dr. K.R. Subhash, CIT DR and Shri Ram Krishn Kedia, Sr. DR
Section 147Section 148

issued at any time in a case for the relevant Assessment Year beginning on or before 1st day of April, 2021, if a notice under section 148 or section 153A or section 153C could not have been issued at that time on account of being beyond the time limit specified ... notices. b. Interplay of Ashish Agarwal with TOLA 108. The Income-tax Act read with TOLA extended the time limit for issuing reassessment notices under section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June 2021. All the reassessment notices under challenge

Praksh Pushparaj Golcha, Andheri (W) vs. Commissioner of Income-Tax (Appeals), NFAC, Delhi

In the result, the appeal is allowed for statistical purposes

ITA 4417/MUM/2023[2011-12]Status: DisposedITAT Mumbai07 Apr 2025AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarpraksh Pushparaj Golcha, V/S. Assistant Commissioner Of 6A, Shivkrupa H Wing, बनाम Income Tax– 24(3), Old Nagardas Road, M/O Finance, Income Tax Andheri(W), Department, National Faceless Mumbai-400 069, Appeal Centre(Nfac), Delhi Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabpg9404H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Mr.Ruturaj H. Gurjar,ARFor Respondent: Shri Mahesh Pamnani,(Sr. DR)
Section 143(3)Section 148Section 250Section 68Section 69C

erred in law as well as under the circumstances of the case in confirming the error of the Assessing Officer in issuing notice under section 148 of the Income tax Act, 1961. 2. THAT the Commissioner of Income tax (Appeals) has erred in law as well as under the circumstances

Jignaben Ruparel, Rajkot vs. ITO, Ward-3, Gandhidham

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

ITA 777/RJT/2024[2015-16]Status: DisposedITAT Rajkot04 Apr 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasaat T/Ita No. 777/Rjt/2024

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 147Section 148

taxable limited. Therefore, return of income was not filed. The assessee has deposited a cash of Rs. 62,36,200/- in Dena Bank, notice under section 148 of the Act was issued. Return of income was filed in reply to the notice declare income of Rs. 42,000/-. The assessee

Kumar Ramesh Sahu, Rajkot, Gujarat vs. ACIT, Circle-2(2), Rajkot, Gujarat

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

ITA 336/RJT/2023[2009-10]Status: DisposedITAT Rajkot04 Apr 2025AY 2009-10

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

For Appellant: Shri M.N. Manvar, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 271(1)Section 54Section 68

before issuing a cheque for loan to above said company. Thereafter, the reasons are recorded and approval was obtained to PCIT-2 and Notice under Section 148 dated 30.03.2016 was issued and served upon the assessee. The assessee requested vide letter dated 17.10.2016 submitted ITA No.336 /RJT/2023 Kumar Ramesh Sahu ... ACIT Asst.Year - 2009-10 that my original return filed on 18.11.2009 will be treated as return in response to notice under Section 148 of the Act. The assessment of the assessee was completed subject to the above remarks and after discussion; the total income of the assessee is recomputed

Rameshwar Ramvilas Sarda, Pune vs. ITO 14(3), Pune

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

ITA 1462/PUN/2024[2017-18]Status: DisposedITAT Pune04 Apr 2025AY 2017-18

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri C. V. DeshpandeFor Respondent: Shri Arvind Desai
Section 148Section 269SSection 271D

erred in levying penalty under section 271D for alleged violation of Section 269SS without taking into consideration the notice under section 148 r.w.s. 147 having been issued suggesting that the Income of Rs. 4,00,000 having been escaped assessment and 3 therefore same amount cannot be subjected to penalty