“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. Bsc C&C Jv, New Delhi vs. ACIT, New Delhi

ITA 2963/DEL/2015[2006-07]Status: DisposedITAT Delhi07 Mar 2025AY 2006-07

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshkuldeep, Vs. Cit(A), Village Kastala, Kasmabad, Nfac, New Delhi Tehsil & District Hapur, Uttar Pradesh (Appellant) (Respondent) Pan:Bumpk4317F Assessee By : None Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 11/03/2026

For Appellant: NoneFor Respondent: Shri Om Prakash, Sr. DR

Section 144Section 147Section 148Section 151

after recording reasons and after taking necessary approval from the Learned Principal Commissioner of Income Tax, Ghaziabad under Section 151 of the Act. Notice under Section 148 of the Act stood issued to the assessee on 26-03-2016 which was duly served upon the assessee through speed post ... assessee had not filed his return of income originally. The assessee did not file any return of income in response to notice under Section 148 of the Act. The assessee merely stated during the course of reassessment proceedings that cash was deposited out of sale proceeds of agricultural land

Sunita Choudhury, Makum Road vs. Income Tax Officer, Ward-1, Tinsukia

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

ITA 136/GTY/2024[2015-16]Status: DisposedITAT Guwahati06 Mar 2025AY 2015-16

Bench: The Ld. Cit(A) Largely On Account Of The Fact That Even At That Stage The Assessee Did Not Respond To The Notices Issued From His Office.

Section 143(2)Section 147Section 148Section 148(2)Section 148ASection 151Section 250Section 68

facts and procedure. 2. For that the Id. CIT(A) ought to have hold that the notice under section 148 of the Act having been issued, mailed and dispatched on 01.04.2021 without following the mandate of section148A of the Act was bad in law and consequently, the order ... assessment passed in pursuance thereof is untenable. 3. For that the Id. CIT(A) erred in not holding that no valid notice under section 148 of the Act was issued by the AO and consequently, the order of re-assessment was bad in law and untenable. 4. For that

Shalini Jagwayan, Jaipur vs. ITO Ward 4(4), Jaipur

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

ITA 987/JPR/2024[2011-12]Status: DisposedITAT Jaipur06 Mar 2025AY 2011-12

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT-VH

Section 139Section 142(1)Section 147Section 148Section 234ASection 250Section 69

section 147 of the IT Act, 1961, after recording reasons for initiating proceedings under section 148 of the IT Act, 1961. Thereafter, notice under section 148 of the IT Act, 1961 was issued to the assessee on 30.03.2018 through registered post, which was duly served upon the assessee. In response ... notice under section 148 of the IT Act, the assessee filed her return of income on 17.04.2018 declaring the income as declared in the original return of income filed on 14.12.2011. The assessee also filed reply and objection on 22.05.2018 against the issuance of notice under section 148, along with

Sheo Ram, Yamuna Nagar vs. Income Tax Officer Ward-4, Yamuna Nagar

In the result, the appeal of the assessee is allowed

ITA 125/CHANDI/2024[2007-08]Status: DisposedITAT Chandigarh06 Mar 2025AY 2007-08

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Rohit Goel, CA and Shri Dhruv Goel, CAFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 148

land which is situated within 8 kms of Municipal Limit, hence he recorded the reasons and issued notice under Section 148 dated 13.09.2012. The AO has thereafter passed an assessment order on 30.03.2014 whereby LTCG liability was determined in the hands of the assessee. Such gain was determined at Rs.3

Samir Navin Shah, Mumbai vs. Income Tax Officer, Circle 19(3), Mumbai

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

ITA 5421/MUM/2024[2012-23]Status: DisposedITAT Mumbai06 Mar 2025AY 2012-23

Bench: Shri Anikesh Banerjee & Omkareshwar Chidarasamir Navin Shah Vs Income-Tax Officer, Circle 19(3) Shreeji Arcade, Shreeji Matru Mandir, Mumbai Chambers, Tata Road No.1 & 2 Opera House, Mumbai-400 004 Pan : Aazps9084M Appellant Respondent Assessee By : Shriv.P. Kothari Respondent By : Ms. Kavitha Kaushik,(Sr Dr)

For Appellant: ShriV.P. KothariFor Respondent: Ms. Kavitha Kaushik,(SR DR)

Section 143(3)Section 147Section 148Section 250

profit at 8% was held to be justified. Consequently, the assessee’s appeal was dismissed. Subsequently, the case was reopened by issuing a notice under Section 148, and the Ld. AO passed a reassessment order under Sections 147/143(3) of the Act. In the reassessment order, the Ld. AO made

Ameya Balkrishna Kulkarni, Mumbai vs. ITO Ward 42(2)(1), Mumbai

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

ITA 4523/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Mar 2025AY 2015-16

Bench: Hon’Ble Br Baskaranhon’Ble Shri Sandeep Gosainameya Balkrishna Kulkarni Vs. Ito, Ward 42(2)(1) 502, Nav Sai Prasad Chsl Kb-922, Kautilya V.B Phadke Road, Opp Bank Bhavan, Bkc, Bandra Of Baroda, Gavanpada, (E), Mumbai. Mulund (E), Mumbai Pan/Gir No. Cgypk9013K (Applicant) (Respondent)

Section 148Section 149Section 149(1)(b)Section 250Section 54Section 69

Technologies Ltd Vs ACIT (2024 ) 162, taxman.com, 225, where in it was held that “The first proviso to section 149 provides that no notice under section 148 shall be issued at any point of time in a case for a relevant assessment year beginning on or before ... April, 2021, if a notice under section 148 could not have been issued at that time on account of being beyond the time limit specified under the provision of clause (b) of sub-section (1) of this section, as it stood immediately before the commencement of the Finance

Income Tax Officer, Income Tax vs. Sumitra Rajeshbhai Jain, Mumbai

In the result, the Cross Objection by the assessee is allowed, while the Revenue’s appeal is dismissed

ITA 2459/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Mar 2025AY 2015-16

Bench: Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Prakash JhunjhunwalaFor Respondent: Shri Pushkaraj Bhangepatil Sr. DR

Section 147Section 148Section 148ASection 149(1)Section 151Section 151ASection 250Section 68

received from DDIT (Inv.), Unit-8(2), Mumbai that the assessee is a beneficiary of bogus capital gains from transaction in penny stocks, notice under section 148 of the Act was issued on 16.06.2021. 8. Subsequently, in view of the decision of the Hon’ble Supreme Court in Union ... order under section 148A(d) of the Act was passed on 29.07.2022 declaring that it is a fit case for issuance of notice under section 148 of the Act. Thereafter, on 29.07.2022, notice under section 148 of the Act was issued by the Jurisdictional Assessing Officer. The assessment order

Radha Madhav Eco-Industrial Park, Valsad vs. Asstt. Commissioner of Income Tax, Central Circle-1, Vapi

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

ITA 632/SRT/2024[2018-19]Status: DisposedITAT Surat05 Mar 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

purposes of this section, specified authority means the specified authority referred to in section 151.] [Conducting inquiry, providing opportunity before issue of notice under section 148. 148A. The Assessing Officer shall, before issuing any notice under section 148,— (a) conduct any enquiry, if required, with the prior approval of specified ... 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

Assistant Commissioner of Income Tax, Central Circle, Vapi vs. Radha Madhav Eco Industrial Park, Vapi

ITA 626/SRT/2024[2019-20]Status: DisposedITAT Surat05 Mar 2025AY 2019-20

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) Vs. The Acit, Radha Madhav Eco-Industrial Park, Central Circle - 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp - Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp - Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

purposes of this section, specified authority means the specified authority referred to in section 151.] [Conducting inquiry, providing opportunity before issue of notice under section 148. 148A. The Assessing Officer shall, before issuing any notice under section 148,- (a) conduct any enquiry, if required, with the prior approval of specified ... 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

Radha Madhav Eco-Industrial Park, Vapi vs. ACIT, Centarl Circle-1, Vapi

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

ITA 41/SRT/2024[2021-22]Status: DisposedITAT Surat05 Mar 2025AY 2021-22

Section 139Section 250

Vivek Khabia, Surat vs. National Faceless Assessment Centre, Delhi

In the result, ground No. 3 is allowed and ground No

ITA 1072/SRT/2024[2018-19]Status: DisposedITAT Surat05 Mar 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 1072/Srt/2024 (Ay 2018-19) (Physical Court Hearing) Vivek Khabia Income Tax Officer, Ward- H.No.1187-90-91, 1089, Office 2(3)(4), Surat, Aaykar Bhavan, बनाम No.411, New Dtc Gheekanta Majura Gate, Surat-395 001 Vs Road, Nr. Bhavani Vad Temple, Haripura, Surat-395 003 [Pan : Avspk 5724 E] अपीलाथ"/Appellant ""थ" /Respondent

Section 133(6)Section 145(3)Section 147Section 148Section 148ASection 151ASection 254(1)Section 28

under section 148A(b) of the Act vide notice issued on 15.03.2022. The AO in para-2 of the assessment order recorded that notice under section 148 of the Act dated 29.03.2022 was issued to file return of income within 30 days. The assessee filed his return of income ... response to notice under section 148 on 3 Vivek Khabia 28.04.2022. Notice under section 143(2) dated 28.09.2022 was issued and served on the assessee. The AO recorded that notice under section 142(1) dated 22.10.2022 was also issued to the assessee for making compliance on 25.10.2022, the assessee sought

ACIT, Central Circle, Vapi vs. Radha Madhav Eco Industrial Park, Vapi

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

ITA 762/SRT/2023[2021-22]Status: DisposedITAT Surat05 Mar 2025AY 2021-22

Section 139Section 250

DCIT, Jaipur vs. Pramod Chand Mahnot, Jaipur

In the result, the appeal of the Department and C

ITA 162/JPR/2023[2012-13]Status: DisposedITAT Jaipur05 Mar 2025AY 2012-13

For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Anup Singh, Addl. CIT-DR fu/kZkfjrh dh vksj ls@

Section 10(38)Section 147Section 148Section 151Section 153CSection 68Section 69C

circumstances of the case and in law, ld. CIT(A)/NFAC has erred in confirming the action of the ld. AO in issuing notice under Section 148 of the Income Tax Act, 1961 without obtaining proper sanction under Section 151 of the Income Tax Act, 1961. The action

Sanjay Balasaheb Shelake, Sangli vs. CIT(A), Sangli

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

ITA 191/PUN/2025[2013-14]Status: DisposedITAT Pune05 Mar 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Umeshkumar M MaliFor Respondent: Shri Ambarnath Bhimrao Khule

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

believe that the assessee has income for the impugned assessment year which has escaped assessment. The AO therefore, after recording reasons, issued a notice under section 148 of the Act, dated 29.03.2021 which was served on the assessee. 4.1 Subsequently, certain information was also called for by issuing notice

Mithu Pal, Kolkata vs. I.T.O., Ward - 50(2), Kolkata

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

ITA 1768/KOL/2024[2012-2013]Status: DisposedITAT Kolkata05 Mar 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 147Section 148Section 250Section 69A

hereunder: “I have carefully perused the appellate documents, submission filed, and order passed by the Ld. JAO. For the appellate year under consideration, notice under section 148 was issued after recording the reasons and obtaining approval of the competent authority. Appellant did not file ROI in response. The information gathered

Jothimuthumariappan, Tirunelveli vs. ITO, Ward-1, Tirunelveli

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

ITA 3026/CHNY/2024[2018-19]Status: DisposedITAT Chennai05 Mar 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.3026/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 Jothimuthumariappan, Vs. The Income Tax Officer, 321B, Main Road, Ward 1, Vickramasingapuram, Tirunelveli S.O., Tirunelveli. Tamil Nadu 627 425. [Pan:Bcfpj0723H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri R. Thulasi Ram, Advocate, : Shri Sathish Kumar, Advocate & Shri Kumar Subramanian, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 26.02.2025 घोषणा की तारीख /Date Of Pronouncement : 05.03.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Respondent: Shri A. Sasikumar, CIT

Section 139(1)Section 147Section 148

assessee did not file return of income under section 139(1) of the Act. Thus, the Assessing Officer issued notice under section 148 of the Act dated 05.04.2022 against which the assessee filed the return of income on 28.05.2022 admitting income of ₹.2,95,920/-. The Assessing Officer issued statutory

Income Tax Officer, Vijayapur vs. Vikram Dalichand Bandari, Vijayapur

In the result the appeal filed by the revenue is dismissed

ITA 1390/BANG/2024[2014-15]Status: DisposedITAT Bangalore05 Mar 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear:2014-15

For Appellant: Sri Sudheendra B.R., A.RFor Respondent: Shri D.K. Mishra, D.R

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

amounting to Rs. 6,84,68,020/- and the respondent assessee has filed CO 32/B/2024 challenging the validity of notice under section 148. 5.4. The ld. A.R. of the assessee has filed paper book along with case law compilation comprising of total 452 pages along with written synopsis of arguments ... Page 8 of 15 6,84,68,020/- in the bank account with Shri Gurubasava Urban Credit Souhardha Co-Operative Bank, Bijapur, the notice under section 148 of the Act dated 31/03/2021 was issued by the AO on a reason to believe that the income chargeable to tax had escaped

Kamlesh Gupta and Sons HUF, Mumbai vs. The Income Tax Officer Ward 19(2)(2), Mumbai

ITA 4080/MUM/2024[2012-13]Status: DisposedITAT Mumbai05 Mar 2025AY 2012-13

Bench: Shri Sandeep Gosain (Jm) & Shri Omkareshwar Chidara (Am) Kamlesh Gupta & Sons Huf Ito-19(2)(2) 95-C, Mittal Towers Piramal Chamber Nariman Point, Churchgate Vs. Lalbaug, Lower Mumbai-400 021. Parel, Mumbai-12. Pan : Aaehk4734K Appellant Respondent

For Appellant: Shri Asif KarmaliFor Respondent: Shri Sumit Mantri

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

further reassessment proceedings that may arise upon availability of any fresh material facts. Therefore, in this case, the time limit of issuance of notice under section 148 of Act is fully justified and is in sync with section 147 of the Act. Thus the Ld. AO was aware that

Rahul Jabarmal Jain, Mumbai vs. Assistant. Commissioner of Income Tax -19(3), Mumbai

In the result, the appeal is accordingly partly allowed for statistical purposes in the above terms

ITA 3525/MUM/2024[2008-09]Status: DisposedITAT Mumbai05 Mar 2025AY 2008-09

Bench: Shri B R Baskaran & Shri Raj Kumar Chauhanrahul Jabarmal Jain Vs. Acit 19(3) 1204/B 12 Floor, Pratiksha Tower, R. 5Th Floor, Piramal Chamber, S. Nimkar Marg, Mumbai Central, Lalbaug, Mumbai-400 012 Mumbai-400 008 Pan: Aempj8236K (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 37

pertinent to examine section 149 and 151 of the Act, which is reproduced as under- “Time limit for notice. 149. [(1) No notice under section 148 shall be issued for the relevant assessment year,— ( a) if four years have elapsed from the end of the relevant assessment year, unless ... 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.] Rahul Jabarmal Jain 5.4. From the plain reading of section 149 of the Act, it is seen that

Ramkaran Singh, Panchkula vs. Income Tax Officer, Ward-3, Panchkula

In the result, the appeal of the assesse is allowed

ITA 439/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh04 Mar 2025AY 2012-13

Bench: him and as such the order passed is arbitrary and unjustified.

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 142(1)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