“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

Mahavir Co Operative Housing Society Limited, Mumbai vs. ITO, Ward, 19(1)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 3409/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 133ASection 142(1)Section 143(2)Section 144BSection 147Section 148Section 148ASection 149Section 149(1)(b)Section 151

taxmann.com 64. 6.2 The Ld.AO subsequently, passed order under section 148A(d) on 26/07/2022 rejecting the objections raised by the assessee. Accordingly notice under section 148 in the new regime was issued under the new regime on 23/08/2022. The assessee was subsequently called upon to furnish details on merits ... before this Tribunal. 7. For the purpose of adjudication, we will first consider legal contention raised by the Ld.AR with regard to the notice under section 148 dated 29/07/2022 being time barred as per the new provisions of section 149(1)(a) as confirmed by the Court in the case

Dmsons Metal Pvt Ltd, Mumbai vs. DCIT, Central Circle-4(1), Mumbai

In the result, appeal of the assessee bearing ITA 762/Mum/2023 is partly allowed

ITA 762/MUM/2023[2015-16]Status: DisposedITAT Mumbai28 Mar 2025AY 2015-16

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeedm Sons Metal Pvt Ltd Vs Dcit, Central Circle-4(1), Mumbai 19Th Floor, Air India Building 502, Peninsula Heights, Juhu Lane, Andheri (West), Mumbai- Nariman Point, Mumbai-400 021 400058 Pan: Aaccd6037D Appellant Respondent

For Appellant: Shri Prayag JhaFor Respondent: Shri. R.R Makwana, Addl.CIT

Section 139(1)Section 147Section 148Section 250

plates. A survey was conducted at the assessee’s premises on 18/12/2017, following which the assessee filed its return of income. Subsequently, a notice under Section 148 of the Act was issued and duly served upon the assessee. In response, the assessee filed the same return as originally submitted under

The Indian Hotels Company Ltd, Mumbai vs. Asst CIT Cir 2(2), Mumbai

Accordingly, Ground No.1 and 4 raised by the Assessee is allowed while all the other grounds raised by the Assessee are dismissed as having being rendered infructuous

ITA 5653/MUM/2011[1998-99]Status: DisposedITAT Mumbai28 Mar 2025AY 1998-99

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

For Appellant: Shri V. Sridharan, Sr. AdvocateFor Respondent: Shri Hemanshu Joshi

Section 143(3)Section 147Section 234BSection 250Section 68

Subsequently, on the basis of report received from Enforcement Directorate reassessment proceedings under Section 147 of the Act were initiated by issuance of notice under Section 148 of the Act on 28/02/2005. The aforesaid reassessment proceedings culminated into passing of the Assessment Order, dated 31/03/2006, under Section 143(3) read ... Assessment Order which reads as under: “Subsequently, on the basis of report received from the Enforcement Directorate, the assessment was reopened by issuing notice under section 148 of the Act on 28.2.2005 on the following grounds:- "As per the show cause notice No. T-4/45-B/SDE(AB/2001

Shahul Hameed, Mananthavady vs. ITO, Ward-2, Kalpetta

In the result, the appeal by the assessee is allowed

ITA 355/COCH/2024[2014-2015]Status: DisposedITAT Cochin27 Mar 2025AY 2014-2015

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Sr.AR

Section 115Section 133ASection 143(3)Section 147Section 148Section 154Section 250Section 69

property over a period of 4 years ranging from the assessment year 2009-10 to the assessment year 2014-15. Accordingly, notice under section 148 of the Act was issued to the assessee on 30/03/2017 and proceedings under section 147 of the Act were initiated. During the reassessment proceedings

Dwarka Prasad Sharma, Kota vs. Income Tax Officer, Delhi

ITA 1455/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Mar 2025AY 2016-17

Bench: Ld. Cit(A), Nfac, Delhi.

For Appellant: Shri Saurav Harsh, AdvFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT (Thr. V.C)

Section 142(1)Section 148Section 250

only submitted that the appellant is 80 years old person not acquainted with the procedures of law. 9. Records reveals that notice under section 148 of the Act was issued to the assessee on 30.3.2021; notices under section 142(1) were issued to the assessee

Nasimbanu Mirza, Ahmedabad vs. The ITO, Ward-3(2)(8)- Currently the ITO, Ward-3(2)(1), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 376/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad27 Mar 2025AY 2011-12

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 376/Ahd/2024 ("नधा"रण वष" / Assessment Year: 2011-12) बनाम/ Nasimbanu Mirza Ito B/67, Mayurpark Society, Ward-3(2)(1), Ahmedabad Vs. Opp. Bibi Talab, Vatva, Daskroi, Ahmedabad, Gujarat - 382440 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Bfkpm6262E (Appellant / Cross Objector) .. (Respondent) Assessee By : Ms. Foziya Saiyed, A.R. Shri Kavan Limbasiya, Sr. Dr Revenue By : 25/03/2025 Date Of Hearing Date Of Pronouncement 27/03/2025

For Appellant: Ms. Foziya Saiyed, A.RFor Respondent: 25/03/2025

Section 142(1)Section 144Section 147Section 148Section 234ASection 271(1)(c)Section 274

case as well as in law on the subject the Learned Assessing Officer has heard in reopening assessment under section 147 by issuing notice under section 148 of the Income Tax Act 1961, 5. Ms. Foziya Saiyed, the ld. A.R. of the assessee submitted that the assessee being a lady

Kavvery Perumal Satheeswaran, Chennai vs. ITO, Ward 1, Tiruchengode

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

ITA 3102/CHNY/2024[2012-13]Status: DisposedITAT Chennai27 Mar 2025AY 2012-13

Bench: Shri Duvvuru Rl Reddyand Shri S.R. Raghunathaआयकरअपीलसं/.Ita No.:3102/Chny/2024 िनधा"रणवष"/Assessment Year:2012-13 Kavvery Perumal Satheeswaran, The Income Tax Officer, 8/66, Thangavel Illam, Cauvery R.S., Vs. Ward 1, Pallipalayam, Erode 638 007. Tiruchengode. [Pan: Asxps2629A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri N.C. Ravi Krishnan, Advocate ""यथ"क"ओरसे/Respondent By : Ms. Gauthami Manivasagam, Jcit सुनवाईक"तारीख/Date Of Hearing : 25.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 27.03.2025 आदेश/ O R D E R Per Duvvuru Rl Reddy, Vice-: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 23.09.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2012-13. 2. We Find That This Appeal Is Filed With A Delay Of 4 Days. The Assessee Filed A Petition For Condonation Of Delay Explaining Reasons For The Said Delay & Prayed For Condonation Of That Delay. On Perusal Of The Condonation Petition & Upon Hearing The Ld. Ar & Ld. Dr, We Find That The Reasons Explained By The Assessee Are Bonafide & Therefore, The Delay Is Condoned & Admitted The Appeal For Adjudication.

For Appellant: Shri N.C. Ravi Krishnan, AdvocateFor Respondent: Ms. Gauthami Manivasagam, JCIT

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 69A

assessee has made huge cash deposits, the Assessing Office reopened the assessment under section 147 of the Act and issued notice under section 148 of the Act dated 28.03.2019. In response to the said notice, the assessee filed return of income on 09.09.2019 declaring total income

Ajay Multi Projects Private Limited, Mumbai vs. DCIT, Circle 4(1)(1), Mumbai, Aaykar Bhawan

In the result, the appeal of the assessee is allowed

ITA 587/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Mar 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Ajay Multi Projects Pvt. Ltd., Dcit, Circle-4(1)(1), 2Nd Floor, C.J. House, 285 Aayakar Bhavan, Vs. Princess Street, Marine Lines, Mumbai-400020. Mumbai-400002. Pan No. Aadca 0338 H Appellant Respondent

For Appellant: Mr. Ram Krishn Kedia, Sr. DRFor Respondent: Mr. Dharan Gandhi

Section 147Section 148Section 148ASection 151Section 234ASection 271(1)(c)Section 69A

issuing a notice under order under Section 148A(d) or issuing a notice under order under Section 148A(d) or issuing a notice under Section 148. (b) Under new regime if income escaping assessment is more (b) Under new regime if income escaping assessment is more (b) Under new regime ... issue a notice under jurisdiction of the Assessing Officer to issue a notice under jurisdiction of the Assessing Officer to issue a notice under Section 148 of the Act. Accordingly, the order, dated of the Act. Accordingly, the order, dated 30/07/2022 passed under 30/07/2022 passed under Section 148A

ACIT Circle-4(3)(1), Mumbai vs. Jmp Securities Pvt Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed and the cross objection filed by the assessee is allowed

ITA 3792/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Mar 2025AY 2017-18

Bench: Shri. Amarjit Singh, Am & Ms. Kavitha Rajagopal, Jm Acit, Circle-4(3)(1) Jmp Securities Pvt. Ltd. Aayakar Bhavan, M. K. Road, 801/806, 8Th Floor, Elite Square, 274, Churchgate, Mumbai – 400020. Vs. Perin Nariman St. Bazar Gate, Fort, Mumbai – 400001. Pan/Gir No. Aaacj8850C (Appellant) : (Respondent) C. O. No. 182/Mum/2024 (Arising Out Of Ita No. 3792/Mum/2024) (Assessment Year: 2017-18) Jmp Securities Pvt. Ltd. Acit, Circle-4(3)(1) 801/806, 8Th Floor, Elite Square, 274, Aayakar Bhavan, M. K. Road, Perin Nariman St. Bazar Gate, Fort, Vs. Churchgate, Mumbai – 400020. Mumbai – 400001. Pan/Gir No. Aaacj8850C (Appellant) : (Respondent) : Shri. Omkandalkar Assessee By Respondent By : Shri. Hemankumar Chimanlal Leuva Cit Dr. Date Of Hearing : 05.02.2025 Date Of Pronouncement : 27.03.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Revenue & Cross Objection Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short)

For Respondent: Shri. Hemankumar Chimanlal Leuva

Section 147Section 148Section 151Section 151ASection 250Section 68Section 69

Court held that sanction of a superior officer to the reasons recorded in terms of section 151 should be obtained before issuing the notice under section 148 of the Act and all jurisdictional requirements are required to be satisfied cumulatively and even if one of the numerous jurisdictional requirements necessary ... issuing the notice under section 148 of the Act are not satisfied, the reopening of an assessment would fail. Hence, in the present facts also since the approval of the specified authority in terms of section 151(ii) of the Act is a jurisdictional requirement and in the absence

ITO Ward 41(1)(1), Mumbai, Kautilya Bhavan, Bkc vs. Arvind Velji Gada, Mumbai

In the result, both the appeals of the assessee and Revenue

ITA 2026/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Mar 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Arvind Velji Gada, Ito Ward 41(1)(1), 1704 12Th Floor, Bellezza Tower, Kautilya Bhavan, Avenue 3, Near Vs. 420, Bhavani Shankar Road, Videsh Bhavan, G Block Bkc, Dadar (West) Bandra Kurla Complex, Bandra Mumbai-400028. East, Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent Assessment Year: 2016-17 Ito Ward 41(1)(1), Arvind Velji Gada, Kautilya Bhavan, Avenue 3, 1704 12Th Floor, Bellezza Tower, 420, Vs. Near Videsh Bhavan, G Block Bhavani Shankar Road, Dadar Bkc, Bandra Kurla Complex, (West) Bandra East, Mumbai-400028. Mumbai-400051. Pan No. Aespg 4212 Q Appellant Respondent

For Respondent: Mr. Ajay R Singh/

Section 68

notice Thus, in the present case, it is discernible that the notice Thus, in the present case, it is discernible that the notice under section 148 of the Act was issued not only in contravention under section 148 of the Act was issued not only in contravention under section 148

Arvind Velji Gada, Mumbai vs. ITO Ward 41(1)(1), Mumbai

In the result, both the appeals of the assessee and Revenue

ITA 1582/MUM/2024[2016-17]Status: DisposedITAT Mumbai27 Mar 2025AY 2016-17

For Respondent: Mr. Ajay R Singh/

Section 68

Mukhtiar Singh, Pinjore, Panchkula vs. Income Tax Officer, Ward-2, Panchkula

The appeal of the assessee is allowed for statistical purposes

ITA 108/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh26 Mar 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ I.T.A. No. 108/Chd/2024 "नधा"रण वष" / Assessment Year: 2012-13

For Appellant: Sh. Tej Mohan Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. D.R

Section 144Section 148

opening is illegal, arbitrary and unjustified. 2. That the Ld. Commissioner of Income Tax (Appeals) has failed to appreciate that no notice under section 148 was ever served on the assessee and as such the order passed is illegal arbitrary and unjustified. 3. That the Ld. Assessing Officer has erred

Govindbhai Bhavandas Patel, Ahmedabad vs. ITO Ward 4(2)(2), Ahmedabad (Existing ITO Ward 4(2)(1), Ahmedabad)

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 256/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad26 Mar 2025AY 2011-12

Bench: Ld. Cit(A) Who Has Set Aside The Exparte Assessment Order Invoking Section 251(1)(A) Of The Act By Observing As Follows:

Section 143(2)Section 144Section 147Section 148Section 234ASection 251(1)(a)Section 271FSection 69A

follows: “In appeal, inter-alia, appellant has stated that appellant was in the USA during financial year under consideration and at the time notice under section 148 of the Act was issued and as such the appellant could not fully and timely comply the notices issued. As per amendment effective

Bramvishma Data & Mailing Services Pvt. Ltd., Ahmedabad vs. The ITO, Ward- 1(1)(2), Ahmedabad

ITA 240/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad26 Mar 2025AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.240/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Bramvishma Data & Mailing The Ito बनाम/ Services Pvt.Ltd. Ward-1(1)(2) V/S. C/O. Divyang Shah & Co.,Cas Ahmedabad – 380 015 201, 2Nd Floor, Devashish Complex Nr. Regenta Central Antarim Hotel, Off. C.G. Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaccb 6364 M अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Maulik Kansara, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 25 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 26 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Maulik Kansara, ARFor Respondent: Shri Rignesh Das, Sr.DR

Section 142(1)Section 144Section 147Section 148Section 250(6)Section 68

Year : 2011-12 Corporate Services Ltd., Chennai, as reflected in Form 26AS. The case was flagged under the Non-Filers Monitoring System (NMS). Notice under section 148 was issued on 21.03.2018, which was returned unserved with the remark "Left". Thereafter, it was served by affixture on 29.03.2018. Notices under section

Dy.Commissioner of Income Tax, Central Circle-1, Aurangabad vs. Parth Multitrade Pvt Ltd, Jalna

In the result, the appeal filed by the Revenue and the CO filed by the assessee are allowed for statistical purposes

ITA 1345/PUN/2024[2008-2009]Status: DisposedITAT Pune26 Mar 2025AY 2008-2009

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2008-09

For Appellant: Shri Anand PartaniFor Respondent: Shri Ajay Kumar Keshari - CIT

Section 143(1)Section 143(3)Section 147Section 148Section 151Section 151(1)Section 68

case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself.” (emphasis supplied by us) 10. Since the Assessing Officer in the instant case has taken the approval

Madanraj Hamirmal Shah, Mumbai vs. ITO, Erode

In the result the appeal of the assessee is partly allowed

ITA 1335/CHNY/2024[2012-13]Status: DisposedITAT Chennai26 Mar 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं./Ita Nos.: 1334 & 1335/Chny/2024 िनधा"रणवष" / Assessment Years: 2011-12 & 2012-13 Madanraj Hamirmal Shah Income Tax Officer, C-405, Royal Samrat, Ward -1(2), S.V. Road,Goregoan West, V. Erode. Mumbai – 400 062. [Pan: Adwpm-2343-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/Appellant By : Shri. P.C. Jain, Advocate & Shri. Mohit Bangani, Advocate ""थ"कीओरसे/Respondent By : Shri. P. Vijaideepan, Jcit सुनवाई की तारीख/Date Of Hearing : 11.02.2025 घोषणा की तारीख/Date Of Pronouncement : 26.03.2025

For Appellant: Shri. P.C. Jain, Advocate &For Respondent: Shri. P. Vijaideepan, JCIT

Section 147Section 148

1335/Chny/2024 The appellant asserts that the Assessing Officer (AO) exceeded jurisdiction by initiating proceedings under Section 147 and issuing notice under Section 148 despite knowing the fact that the appellant being a non-resident with an address in Mumbai as his Indian Address. This, according to appellant, renders the entire ... appeal before us. 6. The ld.AR for the assessee stated that the AO exceeded jurisdiction by initiating proceedings under Section 147 and issuing notice under Section 148 despite knowing the fact that the assessee being a non- resident with an address in Mumbai as his Indian Address. This, according

Madanraj Hamirmal Shah, Mumbai vs. ITO, Erode

In the result the appeal of the assessee is partly allowed

ITA 1334/CHNY/2024[2011-12]Status: DisposedITAT Chennai26 Mar 2025AY 2011-12

For Appellant: Shri. P.C. Jain, Advocate &For Respondent: Shri. P. Vijaideepan, JCIT

Section 147Section 148

Krina Mahesh Maru, Mumbai vs. Income Tax Officer 41(2)(2), Mumbai

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

ITA 6476/MUM/2024[2015-16]Status: DisposedITAT Mumbai26 Mar 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16 Krina Mahesh Maru, Ito-41(2)(2), A-1, Mahesh Krupa Building, Kautilya Bhavan, Vs. Devidayal Cross Road, Mulund Bandra Kurla Complex, West-400080. Mumbai-400020. Pan No. Aeupv 8901 P Appellant Respondent

For Appellant: Mr. Hemanshu Joshi, Sr. DRFor Respondent: Mr. Aditya Ramchandra

Section 148Section 148ASection 151ASection 69

assessment year 2015-16, raising following grounds: 1. On the facts and circumstances of the case and in law the notice under section 148 of the Act dated 24.07.2022 was barred by limitation since it was beyond the surviving time limit Krina Mahesh Maru as held ... meantime, the reassessment proceedings were initiated in my case for AY initiated in my case for AY 2015-16 by issuing a notice under section 148 of the Act dated 16 by issuing a notice under section 148 of the Act dated 16 by issuing a notice under section 148

Rashleela Enterprises Private Limited, Jaipur vs. ACIT Cen Cir 3, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1/JPR/2025[2012-13]Status: DisposedITAT Jaipur25 Mar 2025AY 2012-13

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalrashleela Enterprises Pvt. Ltd., C-5, Krishna Balram, Calgiri Road, Malviya Nagar, Jaipur 302017. Pan No.: Aadcr2594J ...... Appellant Vs.

For Appellant: Mr. Rajeev Sogani, CA, Ld. AR &For Respondent: Mrs. Anita Rinesh, JCIT- Ld. DR

Section 143(3)Section 147Section 148Section 151Section 250Section 35Section 35(1)Section 35(1)(ii)

circumstances of the case and in law, Ld. CIT (A) has erred in confirming the action of the Id. AO in issuing notice under Section 148 of the Act without obtaining proper sanction under Section 151 of the ITA. The action of the Ld. CIT (A) is illegal, unjustified, arbitrary

Ashoka Tanwr, Jaipur vs. ITO, Ward 6(4), Jaipur

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

ITA 966/JPR/2024[2010-2011]Status: DisposedITAT Jaipur25 Mar 2025AY 2010-2011

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalashok Tanwer, F-162, Panchsheel Marg, C-Scheme, Jaipur 302001 Pan No.:Aaxpt8144R ...... Appellant Vs. Income Tax Officer, Ward-6(4), Jaipur ...... Respondent

For Appellant: Mr. Sanjay Godha, CA., Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, JCIT- Ld. DR

Section 133(6)Section 139(4)Section 144Section 148Section 250

Driveshafts (India) Ltd.vs.Income-tax Officer: - “We see no justifiable reason to interfere with the order under challenge. However, we clarify that when a notice under section 148 of the Income Tax Act is issued, the proper course of action for the noticee is to file return