“notice under section 148”

Pravin Harchandrai Agarwal (HUF), Bhiwandi vs. Income Tax Ward 1(1), Kalyan

In the result, the assessee succeeds in the present appeal

Bench: Shri Narender Kumar Choudhryassessment Year: 2011-12 Shri Sanjay Haresh The Income Tax Officer, Mulchandani Ward, 19 (3) (1), 4-C Ajanta Apartments, M L Vs. Piramal Chamber, Dhanukar Marg, Peddar Road, Mumbai – 400013. Mumbai – 40026 Pan – Aadpm 3393 B (Appellant) (Respondent) Present For: Assessee By : Shri Harsh Kapadia & Nitin Khinchi, Ld. Ars Revenue By : Shri Sandeep Jumale, Ld. Sr. Dr Date Of Hearing : 20.11.2025 Date Of Pronouncement : 30.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 08.07.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2011-12. 2. In The Instant Case, The Assessee Along With His Uncle Had Purchased A Flat In Iscon Platinum, Ahmedabad On A Consideration Of Rs. 59,30,000/- Through Cheques. Subsequently, Search Under Section 132 Of The Act Was Conducted By The Investigation Wing, In The Case Of Jp Iscon

showing total income of Rs.3266840/-. The return was processed under Section 143(1). The case was reopened under Section 147 vide notice under Section 148 dated 31.03.2019 against which return was filed by the assessee on 30.04.2019 declaring total income of Rs.32,66,840/- as shown in the original return

Income Tax Officer, Piramal Chambers vs. Dibya Trading Co LLP, Mumbai, Maharashtra

In the result, appeal of the revenue is dismissed and cross- objection of the assessee is also dismissed

Bench: Shri Amarjit Singh & Shri Sunil Kumar Singhassessment Year: 2015-16 Income Tax Officer Dibya Trading Co. Llp

have a bearing on the matter in regard to which the Assessing Officer is required to entertain the belief before he can issue notice under Section 148 of the Act. If there is no rational or intelligible nexus between the reasons and the belief, the exercise undertaken by the Income

M/S Gujarat Enterprises, Mumbai Suburban vs. Income Tax Officer-32(1)(5), Mumbai

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

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawalchandarkishore Vs. Ito, Ward 42(2)(1) Nandkishore Seksaria Kautilya Bhawan, Bkc 70, Seksaria House, Jb Bandra (E) – 400 051. Nagar, Andheri (E), Mumbai – 400 059. Pan/Gir No. Amxps4815N (Applicant) (Respondent)

parte manner. 2. The brief facts of the case are as under: a. The Learned AO issued notice under section 148 on 31.03.2021. In response, the Appellant filed reply on 13.12.2021. b. Thereafter, vide letter dated 10.03.2022, filed before the AO on 11.03.2022, the Appeliant raised objections to the reasons

ACIT 19(1), Mumbai vs. M/S. Orbit Financial Capital, Mumbai

In the result, appeal filed by the Revenue is dismissed as infructuous and Cross Objection of the assessee is allowed

TOLA apply "notwithstanding anything contained in the specified Act." Section 3(1), therefore, overrides the time limits for issuing a notice under section 148 read with Section 149 of the Income-tax Act, d. TOLA does not extend the life of the old regime. It merely provides a relaxation ... Revenue between 1 April 2021 and 30 June 2021 as show- cause notices in terms of Section 148A(b). Thereafter, the Revenue issued notices under section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground

M/S Srimy Jewels Private Limited, Mumbai vs. The Assessing Officer, Assessment Unit, Income Tax Department, Mumbai

In the result the appeal filed by the assessee stands allowed

Bench: Smt Beena Pillaiassessment Year: 2013-14 M/S. Srimy Jewels Dcit Circle 4(3)(1), Private Limited Thrugh Mumbai. Mr. Subodh Modi, Director Of The Appellant Company Je-3010, Vs. Bhrat Diamond Bourse, Bandra Kurla Complex, Bandra East, Mumbai- 400051. Pan: Aagcs0025G Appellant : Respondent

submitted that, the assessment orser under section 143(3) was passed on 23/12/2015 accessessing the loss as declared by the assessee. 2.1. Subsequently, notice under section 148 was issued on 26/07/2022. In response to the notice, assessee filed return of income on 17/05/2023. The assessee also sought for the reasons ... additions, the assessee preferred appeal before the Ld. CIT(A). 3. Before the Ld.CIT(A) assessee challenged valedictory of issuance of notice under section 148 for the year under consideration under the old provisions of the act, that was issued after 01/04/2021 which is beyond the period of limitation

Ashok Amratlal Shah, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, the appeals of the assessee bearing ITA Nos

Bench: Shri.B.R. Baskaran & Shri Anikesh Banerjee- A.Y. 2015-16 - A.Y. 2016-17 - A.Y. 2017-18

said credit society's bank account. Pursuant to this information, proceedings under Section 147 were initiated, and a notice under Section 148 was issued on 23/06/2021, under the old legal framework. However, in light of the Hon’ble Supreme Court's ruling in Ashish Agarwal v. Union of India ... Rs.68,15,933 under Section 69 of the Act, read with Section 115BBE of the Act. The assessee challenged the validity of the notice under Section 148, as well as the approval process, before the Ld. CIT(A), while also disputing the substantive facts of the case. After examining

Rahul Kumar Singh, Ghansoli, Navi-Mumbai vs. Assessing Officer Income Tax Department Ward 28(2)(1), Mumbai, Vashi, Navi-Mumbai

provided fake invoices to the assessee to the tune of Rs. 11.88 lakhs. In view of this information, the Ld. AO issued a notice under section 148 of the Income Tax Act, 1961 (the Act) after obtaining the prior approval of competent authority and passed an order under section 148A