“notice under section 148”

Welspun Captive Power Generation Ltd, Mumbai vs. DCIT Circle 8(3)(1), Mumbai

In the result, appeal of the assessee is allowed

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

Section 3(1) of TOLA overrides section 149 only to the extent of relaxing the time- limit for issuance of a reassessment notice under section 148; (d) TOLA will extend the time-limit for the grant of sanction by the authority specified under section 151. The test to determine whether ... weeks allowed to the assessees to respond to the show cause notices; and (h) The Assessing Officers were required to issue the reassessment notice under section 148 of the new regime within the time-limit surviving under the Income- tax Act read with TOLA. All notices issued beyond the surviving

Nilanjana Arvinder Singh, Mumbai vs. DCIT, Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

return of income itself was not filed by the assessee. Accordingly, on the basis of the aforesaid information, the AO issued notice under section 148 of the Act on 29/06/2021. 9. Subsequently, in view of the decision of the Hon’ble Supreme Court in Union of India vs. Ashish Agarwal ... passed on 28/07/2022 declaring that it is a fit 5 ITAs No.6140 & 6167/Mum/2024 (A.Ys. 2013-14 & 2014-15) case for issuance of notice under section 148 of the Act. Thereafter, on 28/07/2022, notice under section 148 of the Act was issued by the Jurisdictional Assessing Officer. In response

Graceunited Developers Private Limited, Mumbai vs. Income Tax Officer-12(2)(1), Mumbai

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

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

Income-tax Act, 1961 ('Act’) Thank you for filing your return of income for Assessment Year 2013-14 in response to notice under section 148 of the Act, vide Ack. no. 345386641270421 on 27/04/2021. 2. While acknowledging the care and diligence you have taken in preparing the return, there

Graceunited Developes Private Limited, Mumbai vs. Income Tax Officer 12(2)(1), Mumba

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

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

Income-tax Act, 1961 ('Act') Thank you for filing your return of income for Assessment Year 2013-14 in response to notice under section 148 of the Act, vide Ack. no. 345386641270421 on 27/04/2021. 2. While acknowledging the care and diligence you have taken in preparing the return, there

Sudha Agrawal, Mumbai vs. ITO Ward 41(4)(4), Mumbai

In the result, appeal of the assessee bearing ITA No

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

case and in law, the learned Commissioner of Income Tax - Appeals, National Faceless Appeal Centre ought to have held that since the impugned notices under section 148, 148A(b) & 148A(d) have been issues by Jurisdictional Assessing Officer, the subsequent assessment order passed by the Assessing Officer is null ... case and in law, the learned Commissioner of Income Tax - Appeals, National Faceless Appeal Centre ought to have held that since notice under section 148 has been issued without valid DIN, the subsequent assessment order passed by the Assessing Officer is invalid in law. 4. On facts, in circumstances

Jatin Shantilal Shah, Mumbai vs. Income Tax Officer, NFAC Delhi

Appeal is allowed

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

brief facts of the case are that the assessee’s case was reopened under section 147 of the Act by issuingthe notice under section 148 of the Act related to the transactions of penny stockshare during impugned assessment year. The assessee had entered these share transactions belonging to the company

Jatin Shantilal Shah, Mumbai vs. Income Tax Officer, ITO Mumbai

Appeal is allowed

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

brief facts of the case are that the assessee’s case was reopened under section 147 of the Act by issuingthe notice under section 148 of the Act related to the transactions of penny stockshare during impugned assessment year. The assessee had entered these share transactions belonging to the company

Vinod Nihalchand Jain, Mumbai vs. ITO Ward 41(3)(4), Mumbai

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailvinod Nihalchand Jain Ltd., 28, 3Rd Floor, Vishvashanti Chs, Kedarmal Road, Malad (East), Mumbai – 400097 Maharashtra ……………. Appellant Pan – Acipj6853E

file the return of income. Subsequently, on the basis of the information received that the assessee has sold immovable property, notice under section 148 of the Act was issued and proceedings under section 147 of the Act were initiated. As per the information received, the assessee, inter alia, during

M/S G M Builders, Mumbai vs. PCIT(Mumbai), Old-ACIT Circle-22(1), Piramal Chamber, Mumbai

In the result, the appeal by the assessee is allowed

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailm/S. G M Builders, 115, Veena Beena Shipping Center, Turner Road, Bandra West, Mumbai - 400050 Pan – Aaafg1872G ……………. Appellant

ITBA system that the assessee is a non-filler of income despite conducting high-value transactions in respect of transfer of immovable property, notice under section 148 of the Act was issued on 23/03/2021 and proceedings under section 147 of the Act were initiated. In response to notice issued under ... perusal of the record, we find that during the assessment proceedings under section 147 of the Act, the assessee in response to notice under section 148 of the Act submitted that since 1990 there is a dispute amongst the partners of the assessee firm and the matter has been referred