← All Phrases

“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

Durga Kailas Gupta, Malegaon vs. Income Tax Officer, Malegaon

In the result, all four the appeals of the assessee are allowed for statistical purpose

ITA 2436/PUN/2024[2014-15]Status: DisposedITAT Pune04 Mar 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2425, 2427, 2435 & 2436/Pun/2024 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2013-14 & 2013-14 Durga Kailas Gupta, V The Income Tax Officer, New Janta Building, S G.No.425, P.No.5, Chalisgaon Phata, Maharashtra – 423203. Pan: Alapg0234F Appellant / Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 19/02/2025 Date Of Pronouncement 04/03/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Bunch Of Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961; For The Assessment Years Referred Above. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, Therefore, All These Appeals Were Heard Together & Are Being Decided By This Common Order.

Section 148Section 250Section 250(6)

material. She did not file the return of income as her Total Income was below the basic exemption limitation. However, in reply to notice under section 148 of the Act, she has furnished the return of income. There were certain additions made by the Assessing Officer before whom assessee could

Durga Kailas Gupta, Malegaon vs. Income Tax Officer, Malegaon

In the result, all four the appeals of the assessee are allowed for statistical purpose

ITA 2435/PUN/2024[2013-14]Status: DisposedITAT Pune04 Mar 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2425, 2427, 2435 & 2436/Pun/2024 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2013-14 & 2013-14 Durga Kailas Gupta, V The Income Tax Officer, New Janta Building, S G.No.425, P.No.5, Chalisgaon Phata, Maharashtra – 423203. Pan: Alapg0234F Appellant / Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 19/02/2025 Date Of Pronouncement 04/03/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Bunch Of Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961; For The Assessment Years Referred Above. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, Therefore, All These Appeals Were Heard Together & Are Being Decided By This Common Order.

Section 148Section 250Section 250(6)

material. She did not file the return of income as her Total Income was below the basic exemption limitation. However, in reply to notice under section 148 of the Act, she has furnished the return of income. There were certain additions made by the Assessing Officer before whom assessee could

Durga Kailas Gupta, Malegaon vs. Income Tax Officer, Malegaon

In the result, all four the appeals of the assessee are allowed for statistical purpose

ITA 2427/PUN/2024[2017-18]Status: DisposedITAT Pune04 Mar 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2425, 2427, 2435 & 2436/Pun/2024 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2013-14 & 2013-14 Durga Kailas Gupta, V The Income Tax Officer, New Janta Building, S G.No.425, P.No.5, Chalisgaon Phata, Maharashtra – 423203. Pan: Alapg0234F Appellant / Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 19/02/2025 Date Of Pronouncement 04/03/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Bunch Of Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961; For The Assessment Years Referred Above. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, Therefore, All These Appeals Were Heard Together & Are Being Decided By This Common Order.

Section 148Section 250Section 250(6)

material. She did not file the return of income as her Total Income was below the basic exemption limitation. However, in reply to notice under section 148 of the Act, she has furnished the return of income. There were certain additions made by the Assessing Officer before whom assessee could

Durga Kailas Gupta, Malegaon vs. Income Tax Officer, Malegaon

In the result, all four the appeals of the assessee are allowed for statistical purpose

ITA 2425/PUN/2024[2015-16]Status: DisposedITAT Pune04 Mar 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2425, 2427, 2435 & 2436/Pun/2024 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2013-14 & 2013-14 Durga Kailas Gupta, V The Income Tax Officer, New Janta Building, S G.No.425, P.No.5, Chalisgaon Phata, Maharashtra – 423203. Pan: Alapg0234F Appellant / Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 19/02/2025 Date Of Pronouncement 04/03/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Bunch Of Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Income Tax Act, 1961; For The Assessment Years Referred Above. Assessee Has Filed Identical Grounds For All These Years. Since The Issue Involved Is Common, Therefore, All These Appeals Were Heard Together & Are Being Decided By This Common Order.

Section 148Section 250Section 250(6)

material. She did not file the return of income as her Total Income was below the basic exemption limitation. However, in reply to notice under section 148 of the Act, she has furnished the return of income. There were certain additions made by the Assessing Officer before whom assessee could

Income Tax Officer Ward 4 1 Kolkata, Kolkata vs. Panel Commerce Pvt Ltd, Kolkata

In the result, the appeal of the assessee is allowed

ITA 1292/KOL/2023[2013-14]Status: DisposedITAT Kolkata04 Mar 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Panel Commerce Pvt. Ltd. Income Tax Officer, Ward 4(2) 4 Synagogue Street, Aaykar Bhavan, P-7, 8Th Floor, Room No. 814, Chowringhee Square, Kolkata- Vs. Kolkata-700001, 700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aagcp4413P Co No. 1/Kol/2024 (Arising In Ita No.1929/Kol/2023 For A.Y. 2013-14) Panel Commerce Pvt. Ltd. Income Tax Officer, Ward 4(2) 4 Synagogue Street, Aaykar Bhavan, P-7, 8Th Floor, Room No. 814, Chowringhee Square, Kolkata- Vs. Kolkata-700001, 700069, West Bengal West Bengal (Appellant) (Respondent) Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Raghuveer Madanappa, Dr Date Of Hearing: 30.01.2025 Date Of Pronouncement : 04.03.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Raghuveer Madanappa, DR
Section 147Section 148Section 68

Respondent/assessee. We find that the Supreme Court in Rajesh Jhaveri (supra) made it absolutely clear that before an assessing officer issues a notice under section 148, thereby re-opening the assessment under section 147 of the said Act, he must have formed a belief that income had escaped assessment ... Director of IT (Inv.). The second sentence is a direction given by the very same Dy. Director of IT(Inv.) to issue a notice under section 148 and the third sentence again comprises of a direction given by the Addl. CIT to initiate ITA No.1292/KOL/2023 & CO No. 01/KOL/2024 Panel Commerce

Shah Rukh Khan, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, the appeal by the assessee is allowed

ITA 6312/MUM/2024[A. Y. 2012-13 ]Status: DisposedITAT Mumbai04 Mar 2025

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalshah Rukh Khan, 44, Mannat, Bj Road, Bandstand, Bandra, Mumbai - 400050 Pan: Aahpk3293L ……………. Appellant V/S Dcit, Central Circle – 4(2) Kautilya Bhavan, Bandra Kurla Complex, Bandra East, ……………. Respondent Mumbai - 400050 Maharashtra

For Appellant: Shri Aditya AjgaonkarFor Respondent: Ms. Kavitha Kaushik, Sr. DR
Section 148Section 250

after making certain additions/disallowances. 5. Subsequently, after the expiry of 4 years from the end of the relevant assessment year, notice under section 148 of the Act was issued on 31/03/2019. In response to the aforesaid notice, the assessee filed his return of income on 29/04/2019. The AO, vide order ... passed under section 143(3) of the Act. However, after the expiry of 4 years from the end of the relevant assessment year, notice under section 148 of the Act was issued to the assessee. While initiating the re-assessment proceedings, the AO recorded the following reasons for reopening

Dipesh Naresh Sattarshakwala, Surat vs. ITO, Ward -1(2)(1), Surat

In the result, the grounds of appeals raised by the assessee are allowed for statistical purposes

ITA 1235/SRT/2024[2011-12]Status: DisposedITAT Surat03 Mar 2025AY 2011-12

Bench: Shri Pawan Singh, Jidicial Member & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1235/Srt/2024 Assessment Year: (2011-12) (Physical Hearing) Dipesh Naresh Sattarshakwala, I.T.O., B-304, Sweet Residency, Near Ward 1(2)(1), Vs. Sitaram Nagar, Honey Park Road Surat. Adajan, Surat-395009 Pan No. Bjgps 6238 A Appellant/ Assessee Respondent/ Revenue

Section 147Section 148Section 250Section 254(1)

appeal, however, in our considered view, the substantial grounds of appeal relate to (i) validity of reopening under section 147 and issuance of notice under section 148, (ii) if ld. CIT(A) erred in confirming action of Assessing Officer (AO) in making addition of Rs. 98.60 lacs on account

Rajesh Kumar Tiwari, Gonda vs. Addl./Joint/Deputy/ACIT/ITO, NFAC

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

ITA 45/LKW/2025[2017-18]Status: DisposedITAT Lucknow03 Mar 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Rajesh Kumar Tiwari V. Addl./Joint/Deputy/Acit/Ito, Tharakki Patti Nfac, Delhi Gorwaghat, Gonda Tan/Pan:Ajapt7765Q (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sunil Kumar Rajwanshi, D.R. Date Of Hearing: 03 03 2025 Date Of Pronouncement: 03 03 2025 O R D E R

For Appellant: NoneFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 115BSection 147Section 148Section 234ASection 250Section 69A

therefore, reopened the case of the assessee under section 147 of the Income Tax Act, 1961 (hereinafter called “the Act’) after issuing notice under section 148 of the Act. The assessee neither filed the return of income nor responded to the notice under section 148 of the Act. Thereafter

Annasaheb Ramesh Chhaganlal Ajmera Nagari Sahakari Patsanstha Ltd., Dhule vs. ACIT Circle, Dhule

In the result, the appeal of assessee is treated as allowed for statistical purpose

ITA 471/PUN/2024[2012-13]Status: DisposedITAT Pune03 Mar 2025AY 2012-13

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sanket M. JoshiFor Respondent: Shri Ramnath P. Murkunde
Section 139Section 139(1)Section 142(1)Section 143(3)Section 144Section 147Section 148

Dhule. Since the source of cash deposits remained unexplained, the case of the assessee was reopened under section 147 of the Act. Accordingly, notice under section 148 of the Act was issued which was duly served upon the assessee. The assessee, however, failed to file its return of income ... response to the notice under section 148 of the Act and also failed to comply with the notice(s) issued under section 142(1) of the Act asking the assessee to explain the source of the said cash deposit(s) with supporting evidences. The Ld. AO, therefore, proceeded to complete

Ankit Dilip Sethi, Aurangabad vs. ITO Ward 1(1), Aurangabad

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 2000/PUN/2024[2016-17]Status: DisposedITAT Pune03 Mar 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajiv ThakkarFor Respondent: Shri Ramnath P Murkunde - DR
Section 132Section 143(2)Section 144Section 147Section 148Section 69A

further found that the assessee had maintained accounts in the society and entered into financial transactions exceeding the taxable limits." 4.2 Accordingly, notice under section 148 of the Act, was issued and served on the assessee in response to which the assessee filed his Return of Income on 01.03.2022 declaring

Ankit Dilip Sethi, Aurangabad vs. ITO, Ward-1(1), Aurangabad

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 1999/PUN/2024[2014-15]Status: DisposedITAT Pune03 Mar 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajiv ThakkarFor Respondent: Shri Ramnath P Murkunde - DR
Section 132Section 143(2)Section 144Section 147Section 148Section 69A

further found that the assessee had maintained accounts in the society and entered into financial transactions exceeding the taxable limits." 4.2 Accordingly, notice under section 148 of the Act, was issued and served on the assessee in response to which the assessee filed his Return of Income on 01.03.2022 declaring

Ankit Dilip Sethi, Aurangabad vs. ITO, Ward 1(1), Aurangabad

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 1998/PUN/2024[2013-14]Status: DisposedITAT Pune03 Mar 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajiv ThakkarFor Respondent: Shri Ramnath P Murkunde - DR
Section 132Section 143(2)Section 144Section 147Section 148Section 69A

further found that the assessee had maintained accounts in the society and entered into financial transactions exceeding the taxable limits." 4.2 Accordingly, notice under section 148 of the Act, was issued and served on the assessee in response to which the assessee filed his Return of Income on 01.03.2022 declaring

Heggur Nanjundappa Vishwanath, Bangalore vs. DCIT, Circle-7(1)(1), Bangalore

The appeal of the assessee is allowed

ITA 55/BANG/2025[2015-16]Status: DisposedITAT Bangalore03 Mar 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadavassessment Year : 2015-16

For Appellant: Shri Deepak Chopra, CAFor Respondent: Smt. Neha Sahay, Jt.CIT(DR)(ITAT), Bengaluru
Section 148Section 148A(1)(d)Section 149Section 149(1)(b)

which has been interpreted by the Hon’ble Bombay High Court in Hexaware Technologies Ltd. (supra) is reproduced below :- “149. (1) No notice under section 148 shall be issued for the relevant assessment year,— (a) if three years have elapsed from the end of the relevant assessment year, unless ... which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more for that year: Provided that no notice under section 148 shall be issued at any time in a case for the relevant assessment year beginning on or before 1st day of April

Leader Electric Co., Rajkot vs. The PCIT-1, Rajkot

In the result, the appeals of the assessees are dismissed

ITA 377/RJT/2024[2015-16]Status: DisposedITAT Rajkot28 Feb 2025AY 2015-16

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.376 & 377/Rjt/ 2024 ("नधा"रणवष" / Assessment Year: (2014-15& 2015-16) (Hybrid Hearing) Leader Electric Co. The Pcit – 1, Vs. Dindayal Industries Estates, Aayakar Bhavan, Race Course Ring Aji Vasahat, Opp. Gamara Hostel, Road, Rajkot - 360003 Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfl6072C (Appellant) (Respondent)

For Appellant: ShriD. M. Rindani, Ld. ARFor Respondent: ShriSanjay Punglia, Ld. CIT (DR)
Section 147Section 2Section 263

that in this case the return of income was filed declaring total income of Rs. 29,114/- on 26.02.2015. The case was reopened notice under section 148 of the Act was issued to the assessee, assessment proceeding initiated u/s. 147 r.w.s. 144 B of the Act. during the course assessment

Leader Electric Co., Rajkot vs. The PCIT-1, Rajkot

ITA 376/RJT/2024[2014-15]Status: DisposedITAT Rajkot28 Feb 2025AY 2014-15
For Appellant: ShriD. M. Rindani, Ld. ARFor Respondent: ShriSanjay Punglia, Ld. CIT (DR)
Section 147Section 2Section 263

that in this case the return of income was filed declaring total income of Rs. 29,114/- on 26.02.2015. The case was reopened notice under section 148 of the Act was issued to the assessee, assessment proceeding initiated u/s. 147 r.w.s. 144 B of the Act. during the course assessment

Seema Lunawat, Ratlam vs. Income Tax Officer, Mandsaur

ITA 300/IND/2024[2011-12]Status: DisposedITAT Indore28 Feb 2025AY 2011-12
Section 139Section 147Section 148Section 151(1)

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE MS. SUCHITRA RAGHUNATH KAMBLE, JUDICIAL

Income Tax Officer-1(2), Indore vs. Divine Infracreation and Trading Private Limited, Mumbai

The appeal stands dismissed

ITA 272/IND/2024[2010-11]Status: DisposedITAT Indore28 Feb 2025AY 2010-11

Bench: Shri B.M. Biyani

Section 143(3)Section 144Section 148Section 68Section 68(1)

submitted that the original assessment was completed under section 143(3) of the Act on 15-2- 1999, that subsequently, a notice under section 148 of the Act was issued on 25-2-2003, which was beyond four years from the end of the assessment year, that there ... under section 10(23C)(vi) of the Act and accordingly on the basis of the reasons recorded under section 147 of the Act, notice under section 148 of the Act was issued and served upon the assessee on 4.3.2010. Accordingly the due date for furnishing of the return of income

Assistant Commissioner of Income Tax Circle-1, Bareilly vs. Wave Distilleries and Breweries Limited, Bareilly

Appeals of the Department stand dismissed

ITA 153/LKW/2023[2013-14]Status: DisposedITAT Lucknow28 Feb 2025AY 2013-14

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: S/Shri Salil Kapoor, Vibhu Jain and Sumit Lalchandani, AdvocatesFor Respondent: Smt. Richa Rastogi, CIT (DR)
Section 115JSection 148

circumstances of the case, the reason to believe as to escapement of income is not formed by the Assessing Officer but the notice under section 148 of the Act is issued on the directions of Higher Authority/Audit ITA Nos.153 to 157/LKW/2023 C.O. Nos.23, 24, 21,22 and 25/LKW/2023 Page ... That in view of the facts and circumstances of the case and in law. the assessment order dated 29.03.2022 passed pursuant to the notice under Section 148 of the Act is illegal, bad in law and without jurisdiction as the reopening in instant case is only on account of change

Balwant Singh Dhindsa, Adv. So Kartar Singh, #185 Street No. 11, Punia Colony, Sangrur, Punjab vs. ITO Ward Sangrur, Punjab

In the result, appeal of the assessee is

ITA 800/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh28 Feb 2025AY 2012-2013
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, JCIT, Sr.DR
Section 142(1)Section 144Section 148Section 246ASection 250Section 253Section 69A

previous year period is from 01.04.2011 to 31.03.2012. 2. Factual Matrix 2.1 That as per information available with the Income Tax Department, a notice under Section 148 r.w.s.147 came to be issued to the assessee on 29.03.2019 and was served accordingly. It was stated therein that the assessee during assessment ... made certain cash transactions with Punjab National Bank. 2.2 That the assessee has not filed his return of income in compliance to the notice under Section 148 of the Act. 2.3 That the notice(s) under Section 142(1) of the Act were issued on various date(s) and that

ACIT, Circle, Panchkula vs. M/S Haryana Vidyut Prasaran Nigam Ltd., Panchkula

In the result, we upheld the

ITA 1458/CHANDI/2019[2008-09]Status: DisposedITAT Chandigarh28 Feb 2025AY 2008-09

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Harish Nayyar C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 10Section 143(2)Section 143(3)Section 147Section 148Section 14ASection 194ASection 36Section 40

Briefly the facts of the case are that the assessment was originally completed under section 143(3) vide order dt. 30/11/2010. Thereafter notice under section 148 dt. 23/01/2013 was issued after recording reasons which were duly served on the assessee. In response to the notice, the assessee filed its return ... also held disallowable under section 40(a)(ia)of the Act and this was one of the reason recorded before issuance of notice under section 148 of the Act. Thereafter, during the reassessment proceedings, the AO accepted the submissions of the assessee that no tax was required to be deducted