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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

Krishnasamy Sathyanathan Ramprasad, Chengalpattu vs. Income Tax Officer, Non Corp. Ward 22(4), Tambaram.

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

ITA 3364/CHNY/2024[2018-19]Status: DisposedITAT Chennai28 Feb 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.3364/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 Krishnasamy Sathyanathan Vs. The Income Tax Officer, Ramprasad, No. 174, Anna Salai, Non Corporate Ward 22(4), Chengalpattu 603 001. Tambaram, Chennai. [Pan:Aempr9403C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R.S. Lakshmi Narayana, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 24.02.2025 घोषणा की तारीख /Date Of Pronouncement : 28.02.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: Shri R.S. Lakshmi Narayana, AdvocateFor Respondent: Shri A. Sasikumar, CiT
Section 142(1)Section 147Section 148Section 69Section 69A

assessee. Further, rental income admitted at ₹.9,68,000/- which has not been reflected in the return filed in response to notice under section 148 of the Act is brought to tax under the head 3 I.T.A. No.3364/Chny/24 income from house property. On appeal, the ld. CIT(A) dismissed

Kanyakumari Habitat for Humanity, Kanyakumari vs. ITO Exemptions Ward, Tirunelveli

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

ITA 3328/CHNY/2024[2018-19]Status: DisposedITAT Chennai28 Feb 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.3328/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 Kanyakumari Habitat For Humanity, Vs. The Income Tax Officer, 72, Jacob Street Nesamany Nagar, Exemptions Ward, Nagerkoil, Kanyakumari 629 001. Tirunelveli. [Pan:Aactk1063D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Girish Kumar, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 24.02.2025 घोषणा की तारीख /Date Of Pronouncement : 28.02.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.11.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2. The Assessee Raised 14 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made Under Section 69A Of The Income

For Appellant: Shri Girish Kumar, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(2)Section 147Section 148Section 69A

Assessing Officer observed that the assessee made cash deposits amounting to ₹.65,78,098/- and no return of income filed. A notice under section 148 of the Act issued on the assessee and in response to which, the assessee filed return of income showing NIL income. Against the statutory notices

Arthi Baliga, Chennai vs. ACIT, NFAC, Delhi

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

ITA 1559/CHNY/2024[2017-18]Status: DisposedITAT Chennai28 Feb 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1559/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Arthi Baliga, Vs. The Principal Commissioner Of No. 15, Flat No. 3-C, Coral Woods Income Tax, Chennai-4, Apartment, Sri Ram Nagar, South Chennai. Street, Alwarpet, Chennai 600 018. [Pan:Bkjpb5416P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ravi Kannan, Advocate & Shri Varun Ranganathan, Advocate ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 05.12.2024 घोषणा की तारीख /Date Of Pronouncement : 28.02.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax, Chennai-4, Chennai For The Assessment Year 2017-18 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Ravi Kannan, Advocate &For Respondent: Shri Nilay Baran Som, CIT
Section 143(3)Section 147Section 148Section 263

Jurisdictional Assessing Officer recorded the reason and reproduced the same at page 2 of the assessment order. Accordingly, the Assessing Officer issued notice under section 148 of the Act and in response to the notice, the assessee filed revised return of income on 18.05.2021 admitting income

Capco Finance and Investment Private Limited, Mumbai vs. ITO Ward 15 1 1 Mumbai, Mumbai

In the result appeal filed by the assessee stands allowed on

ITA 44/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Feb 2025AY 2012-13

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

Section 249(2)Section 271FSection 69

dealing in listed and unlisted securities. For your under consideration assessee did not file any return of income and therefore the Ld.AO issued notice under section 148 of the act on 22/03/2019. The Ld.AR submitted that during the assessment proceedings, assessee informed vide letter dated 07/09/2018 regarding strike ... admitted fact that, the said information was provided to the authorities by assessee vide letter dated 07/09/2018. Despite such intimation the Ld.AO issued notice under section 148 of the act in the name of non- existent company on 29/05/2019. 5.1 It is noted that the strike off of assessee

Rakesh Mulchand Kothari, Mumbai vs. Income Tax Officer, WD-26(2)(5), Mumbai

ITA 6598/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Feb 2025AY 2015-16

Bench: Due Date For Filing The Return Of Income U/S 139(4) Viz. 31/03/2017, Thereby The Notice U/S.148 & Consequential Reassessment Order Passed U/S.147 Is Bad In Law;

For Respondent: Shri Prakash Jhunjhunwala
Section 10(38)Section 131Section 139(4)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

Appellate proceedings, the Assessee challenged reopening of the assessment under Section 148 of the Act, inter alia, on the ground that the notice under Section 148 of the Act was issued to the Assessee before the expiry of due date to file the return of income under Section ... notice under Section 148 of the Act could not have been issued since the time limit for issuing the notice under Section 142(1) of the Act as well as the time limit for filing of the belated return was available with the Assessee. Reliance was placed by the Assesseeon

Rumina Shamsuddin Wallani, India vs. ITO 19(1)(5), Pirmal Chambers

In the result the appeal filed by the assessee stands allowed

ITA 5057/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Feb 2025AY 2017-18

Bench: Smt. Beena Pillai ()

Section 148Section 148ASection 56(2)(vii)Section 69

directions of Hon’ble Supreme Court in case of UOI vs Ashish Agarwal reported in (2022) 138 taxmann.com 64. Subsequently, notice under section 148(b) was issued on 30/05/2022. In response to the said notice issued, the assessee vide letter dated 13/06/2022 filed her response as under: "Your notice ... Ld.AO subsequently, passed order under section 148A(d) on 30/07/2022 by rejecting the objections raised by the assessee. Accordingly notice under section 148 was issued under the new regime on 30/07/2022. The assessee was subsequently called upon to furnish details on merits of the addition. Ld.AO after considering assessee

ACIT 19(3), Mumbai vs. Ramchand Thakurdas Jhamtani, Mumbai

ITA 3553/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Feb 2025AY 2014-15

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

For Appellant: Shri Dharan GandhiFor Respondent: Shri R. R. Makwana
Section 144BSection 147Section 148Section 148ASection 250

Assessment Year 2014-2015. 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 2014-2015 on 07/06/2021 (i.e., after the expiry of 4 years but before ... 24/07/2022, and the same was followed by issuance of notice dated 24/07/2022, 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 6 years from the end of the relevant assessment year. 6. The contention

ACIT-19(3), Mumbai vs. Ramchand Thakurdas Jhamtani, Thane

Accordingly, all the grounds raised by the Revenue in the departmental appeal in relation to the relief granted by the CIT(A) on merits are dismissed as having been rendered infructuous

ITA 3552/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Feb 2025AY 2015-16

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

For Appellant: Shri Dharan GandhiFor Respondent: Shri R. R. Makwana
Section 144BSection 147Section 148Section 148ASection 149Section 149(1)Section 250

Assessment Year 2015-2016. The Assessee has filed cross-objection. 2. The relevant facts in brief are that notice under Section 148 of the Act was issued to the Assessee for the Assessment Year 2015-2016 on 30/06/2021 (i.e., after the expiry of 4 years but before the expiry ... income had escaped assessment. Thereafter, order under Section 148A(d) of the Act was passed on 27/07/2022 which was followed by issuance of notice under Section 148 of the Act on 27/07/2022. The reassessment proceedings culminated into passing of the Assessment Order, dated 29/05/2023, passed under Section 147 read with

ACIT-19(3), Mumbai vs. Ramchand Thakurdas Jhamtani, Thane

Accordingly, all the grounds raised by the Revenue in the departmental appeal in relation to the relief granted by the CIT(A) on merits are dismissed as having been rendered infructuous

ITA 3551/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Feb 2025AY 2017-18

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

For Appellant: Shri Dharan GandhiFor Respondent: Shri R. R. Makwana
Section 144BSection 147Section 148Section 148ASection 151Section 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 28/06/2021 (i.e., after the expiry of 3 years but before 30/06/2021 ... Income Tax was the Specified Authority for seeking approval for passing order under Section 148A(d) of the Act and issuance of notice under Section 148 of the Act (new regime) for the Assessment Year 2017-18. 6. In this regard we deem it appropriate to refer to judgment

Aptivaa Middle East Fze, Mumbai vs. Deputy Commission of Income Tax, Circle 1(1)(2), International Taxation, Mumbai

In the result of the file by the assessee stands partly allowed as indicated hereinabove

ITA 2791/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Feb 2025AY 2015-16

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 149(1)(b)Section 271(1)(c)Section 274Section 6(3)(ii)

That on facts and in the circumstances of the case and in law, the Ld. AO has erred in issuing notice under section 148 as the same cannot be issued as per the provisions of section 149(1)(b) in the absence of any income escaped assessment represented ... taxmann.com 64. The Ld.AO subsequently, passed order under section 148A(d) on 29/07/2022 by rejecting the objections raised by the assessee. Accordingly, notice under section 148 was issued on 29/07/2022 for all years under consideration. 2.3 A draft assessment order was subsequently passed on 29/05/2023 for all the years under

Aptivaa Middle East Fze, Dubai, United Arab Emirates vs. Deputy Commissioner of Income Tax, Circle 1(1)(2), International Taxation, Mumbai, Maharastra

In the result of the file by the assessee stands partly allowed as indicated hereinabove

ITA 2357/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Feb 2025AY 2016-17

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 149(1)(b)Section 271(1)(c)Section 274Section 6(3)(ii)

That on facts and in the circumstances of the case and in law, the Ld. AO has erred in issuing notice under section 148 as the same cannot be issued as per the provisions of section 149(1)(b) in the absence of any income escaped assessment represented ... taxmann.com 64. The Ld.AO subsequently, passed order under section 148A(d) on 29/07/2022 by rejecting the objections raised by the assessee. Accordingly, notice under section 148 was issued on 29/07/2022 for all years under consideration. 2.3 A draft assessment order was subsequently passed on 29/05/2023 for all the years under

Aptivaa Middle East Fze, Dubai, United Arab Emirates vs. Deputy Commissioner of Income Tax, Circle 1(1)(2), International Taxation, Mumbai, Maharastra

In the result of the file by the assessee stands partly allowed as indicated hereinabove

ITA 2355/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Feb 2025AY 2017-18

Bench: Smt. Beena Pillai () & Ms. Padmavathy S. ()

Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 149(1)(b)Section 271(1)(c)Section 274Section 6(3)(ii)

That on facts and in the circumstances of the case and in law, the Ld. AO has erred in issuing notice under section 148 as the same cannot be issued as per the provisions of section 149(1)(b) in the absence of any income escaped assessment represented ... taxmann.com 64. The Ld.AO subsequently, passed order under section 148A(d) on 29/07/2022 by rejecting the objections raised by the assessee. Accordingly, notice under section 148 was issued on 29/07/2022 for all years under consideration. 2.3 A draft assessment order was subsequently passed on 29/05/2023 for all the years under

Susheel Kumar Govindram Saraff, Mumbai vs. ITO, International Taxation Ward-4(2)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 631/MUM/2023[2017-18]Status: DisposedITAT Mumbai28 Feb 2025AY 2017-18

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

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 147Section 148Section 153Section 68

appeal before the Tribunal. 4. At the outset, the Ld.AR submitted that, the assessee raised various legal grounds challenging validity of issuance of notice under section 148, to be bad in law, as well as consequential assessment order passed, being without following principles of natural justice in the original ground ... issue raised by assessee in the additional grounds are legal issue challenging that reasons recorded is not by the same officer who issued notice under section 148 of the Act. It is thus submitted by the Ld.AR that that the reasons recorded are subsequent to issuance of reopening and therefore

Anmol Kumar, Bhagalpur vs. ITO Ward 2(1), Begusarai

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

ITA 343/PAT/2023[2017-18]Status: DisposedITAT Patna27 Feb 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 343/Pat/2023 Assessment Year: 2017-2018 Anmol Kumar,……………………….……….....Appellant Tulsipur, Via Khirik Bazar, Naugachhiya, Bhagalpur-853202, Bihar [Pan:Aqupk8693D] -Vs.- Income Tax Officer,……….………………….Respondent Ward-2(1), Begusarai, Begusarai-851101, Bihar Appearances By: Shri Sudeep Sinha, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 30, 2024 Date Of Pronouncing The Order: February 27, 2025 O R D E R

Section 148Section 69A

Bank account and also had received interest income but failed to file the return of income. Scrutiny assessment proceedings were initiated and notice under section 148 dated 30.03.2021 was issued by the ld. Assessing Officer to the assessee and the same was served on the assessee. The assessee was given

Bajrang Lal, Ujjain, M.P vs. The Assessment Unit, NFAC, Delhi

In the result appeal of the assessee is partly allowed

ITA 637/IND/2024[2017-18]Status: DisposedITAT Indore27 Feb 2025AY 2017-18

Bench: Shri Manish Borad

Section 147Section 148Section 151Section 69A

confirming the action of the Ld Assessing Officer in reopening the case of the appellant for Assessment Year 2017-18 vide issuance of notice under section 148 of the Act on 27-07-2022 i.e. after three years from the end of relevant assessment year even when the correct amount

Bajrang Lal, Ujjain, M.P vs. The Assessment Unit, NFAC, Delhi

In the result appeal of the assessee is partly allowed

ITA 634/IND/2024[2017-18]Status: DisposedITAT Indore27 Feb 2025AY 2017-18

Bench: Shri Manish Borad

Section 147Section 148Section 151Section 69A

confirming the action of the Ld Assessing Officer in reopening the case of the appellant for Assessment Year 2017-18 vide issuance of notice under section 148 of the Act on 27-07-2022 i.e. after three years from the end of relevant assessment year even when the correct amount

Deputy Commissioner of Income Tax, Chandigarh vs. Winsome Textile Industries Ltd, Chandigarh

ITA 556/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12
For Respondent: The DCIT
Section 115JSection 143(1)Section 143(3)Section 147Section 148

rate gains earned by the assessee on GDR proceeds which were not repatriated to India immediately and thus income has escaped assessment and notice under section 148 was issued on 26/03/2017. Thereafter after considering the submissions filed by the assessee, the AO framed the assessment under section 143(3) r.w.s ... income to the extent of Rs.2,29,15,034/- has escaped assessment within the meaning of Section 147 of the Act and another notice under section 148 was issued on 31/03/2018 which was served on the assessee on the said date. 6. In response to the notice under section 148

Winsome Textile Industries Limited, Chandigarh vs. Asstt. Commissioner of Income Tax, Circle-4(1), Chandigarh

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

ITA 528/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12

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

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Ved Parkash Kalia Sr. DR
Section 115JSection 143(1)Section 143(3)Section 147Section 148

rate gains earned by the assessee on GDR proceeds which were not repatriated to India immediately and thus income has escaped assessment and notice under section 148 was issued on 26/03/2017. Thereafter after considering the submissions filed by the assessee, the AO framed the assessment under section 143(3) r.w.s ... extent of Rs. 2,29,15,034/- has escaped assessment within the meaning of Section 147 of the Act and another notice under section 148 was issued on 31/03/2018 which was served on the assessee on the said date. 6. In response to the notice under section 148, the assessee

Jatin Dilipbhai Jani, Ahmedabad vs. The ITO, Ward-1(1)(1), Ahmedabad

In the result, the appeal of the assessee in ITA

ITA 892/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad27 Feb 2025AY 2017-18

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

For Appellant: Revenue by Shri V. Nandakumar, CIT-DR and Shri ashokkumar Suthar, Sr.DR
Section 143(2)Section 143(3)Section 147Section 148Section 250(6)

possession of the AO of huge deposits in the bank account of the assessee, the case of the assessee was reopened by issuing notice under section 148 of the Act and thereafter after giving due opportunity of hearing to the assessee, the AO framed assessment treating the deposits ... fact on record, noted by the AO also, that the assessee had filed return of income in response to the notice under section 148 of the Act, but the AO did not issue any notice under section 143(2) of the Act thereafter to the assessee . 8. The ld.DR

Jatin Dilipbhai Jani, Ahmedabad vs. The ITO, Ward-1(1)(1), Ahmedabad

In the result, the appeal of the assessee in ITA

ITA 891/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad27 Feb 2025AY 2012-13

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

For Appellant: Revenue by Shri V. Nandakumar, CIT-DR and Shri ashokkumar Suthar, Sr.DR
Section 143(2)Section 143(3)Section 147Section 148Section 250(6)

possession of the AO of huge deposits in the bank account of the assessee, the case of the assessee was reopened by issuing notice under section 148 of the Act and thereafter after giving due opportunity of hearing to the assessee, the AO framed assessment treating the deposits ... fact on record, noted by the AO also, that the assessee had filed return of income in response to the notice under section 148 of the Act, but the AO did not issue any notice under section 143(2) of the Act thereafter to the assessee . 8. The ld.DR