“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

Amaravati Agro Ltd., Pondicherry vs. ACIT, Circle-1, Pondicherry

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

ITA 2275/CHNY/2024[2013-14]Status: DisposedITAT Chennai19 Dec 2024AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2275/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 Amaravati Agro Limited, Vs. The Assistant Commissioner Of 2 Le Bois, Abhishekapakkam, Income Tax, Pondicherry 605 007. Circle 1, Pondicherry. [Pan:Aaaca4655Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Balasubramanian, Advocate ""थ" की ओर से/Respondent By : Shri K. Rohan Raj, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 03.12.2024 घोषणा की तारीख /Date Of Pronouncement : 19.12.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 09.07.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2013-14. 2. At The Outset, The Ld. Ar Shri K. Balasubramanian, Advocate Submits That The Assessee Raised A Legal Issue Of Reopening Of Assessment Under Section 147 Of The Income Tax Act, 1961 [“Act” In 2

For Appellant: Shri K. Balasubramanian, AdvocateFor Respondent: Shri K. Rohan Raj, Addl. CIT

Section 143(3)Section 147Section 148Section 154Section 54E

same claim under section 54EC of the Act has been issued on the assessee and the same having not been dropped, issue of notice under section 148 of the Act dated 24.01.2020 on the very same issue for the same AY is not proper in view of the decision ... been issued to rectify the error in the assessment order, for the very same reason, the Assessing Officer has no jurisdiction to issue notice under section 148 of the Act and prayed to quash the assessment order passed under section 147 r.w.s. 144 of the Act dated 20.09.2021. 3 I.T.A

Shri. Mudiyappa, Gangavathi vs. Income Tax Officer, Ward-1, Koppal

In the result, the appeals of the Revenue and assessee are allowed for statistical purpose

ITA 1506/BANG/2024[2018-19]Status: DisposedITAT Bangalore19 Dec 2024AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

For Appellant: Shri. Veeranna M. Murgod, CAFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bengaluru

Section 133(6)Section 148Section 194CSection 44A

rival submissions, we note that the assessee did not file return of income under section 139 of the Act and after receiving notice under section 148 of the Act, assessee filed return of income declaring turnover of Rs.97,25,330/- under section 44AD of the Act, and claimed

Income Tax Officer, Ward-1, Koppal vs. Mudiyappa, Malligevada

In the result, the appeals of the Revenue and assessee are allowed for statistical purpose

ITA 1460/BANG/2024[2018-19]Status: DisposedITAT Bangalore19 Dec 2024AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

For Appellant: Shri. Veeranna M. Murgod, CAFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bengaluru

Section 133(6)Section 148Section 194CSection 44A

Jagjit Singh, Patiala vs. Income Tax Officer, Ward-2, Patiala

In the result we set aside the impugned order and remand the case back to the file of Ld

ITA 105/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh18 Dec 2024AY 2011-12

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Bearing No. Itba/Nfac/S/250/2023- 24/1058720011(1) Dt. 13/12/2023 Of The Ld. Cit(A) Passed Under Section 250 Of The Act Which Is Hereinafter Referred To As The “Impugned Order”. The Relevant Assessment Year Is 2011-12 & The Corresponding Previous Year Period Is From 01/04/2010 To 31/03/2011. 2. Factual Matrix

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 17Section 22Section 250Section 253

consequently proceedings under section 147 of the Act were intiated against the assessee as source of the investment remained unexplained. 2.2 A notice under section 148 of the Act dt. 29/03/2018 was issued with the prior approval of the appropriate authority. 2.3 That the notice was served on the assessee

Smt. Arunjeet Kaur, Chandigarh vs. ITO-Ward-4(5), Chandigarh

Appeal of the assessee is allowed

ITA 280/CHANDI/2021[2012-13]Status: DisposedITAT Chandigarh18 Dec 2024AY 2012-13

Bench: This Tribunal. The Relevant Assessment Year Is 2012-13 & The Corresponding Previous Year Period Is From 01.04.2011 To 31.02.20212. The Assessee Is Aggrieved By The Order Bearing No.Itba/Nfac/S/250/2021-

For Appellant: Shri Parikshit Aggarwal, CA &For Respondent: Shri Vivek Vardhan, JCIT, Sr.DR

Section 142(1)Section 143(2)Section 148Section 246ASection 250Section 253

information that the assessee had purchased immovable property for a total consideration of Rs.59,40,000/- during the assessment year 2012-13 a notice under Section 148 of the Act was issued to the assessee by revenue on 27.03.2019 i.e., by the ITO, Ward 11(5), Muktsar after obtaining prior ... declared as agriculture income thereby requesting that the return of income may kindly be treated to have been filed in response to Notice under Section 148. 2.4 That thereafter, notice under Section 143(2) and 142(1) alongwith questionnaire was issued on 11.07.2019 and that the same was served upon

Dipikaben Alpeshkumar Patel Legal Heir of Late Alpeshkumar Jagdishbhai Patel, Anand vs. The Income Tax Officer, Ward-1, Anand

In the result, the appeal of the assessee is allowed

ITA 1687/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2013-14

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Arti N Shah, A.RFor Respondent: Shri V. K. Mangla, Sr. D.R

Section 142(1)Section 144Section 148Section 234ASection 69A

bank account during the year, which did not align with his profile as a non-filer. Consequently, the AO issued a notice under Section 148 on 09.04.2019. The assessee failed to respond, prompting the AO to issue another notice under Section 142(1) on 29.09.2020. In response, the assessee submitted

Shambhavee Shashikant Kadam, Andheri (West) vs. National Faceless Assessment Centre, New Delhi

The appeal of the assessee is partly allowed

ITA 4748/MUM/2024[2017-18]Status: DisposedITAT Mumbai18 Dec 2024AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri Bhangepatil Pushkaraj

Section 147Section 148Section 148ASection 151Section 234BSection 56(2)(vii)Section 69

contentions with regard to the notice issued under section 148 of the Act. The first contention of the ld. AR is that the notice under section 148 is issued by the ITO Ward 24(1)(1), Mumbai whereas the assessee has filed the return of income in Satara. Accordingly ... submitted that the notice which is issued by non-jurisdictional AO is invalid. The second contention of the ld. AR is that the notice under section 148 has been issued without getting the approval of appropriate authority as per the provisions of section 151 of the Act. For the purpose

ITO Ward 14(2)(1), Mumbai vs. Malvika Herbopharma Private Limited, Mumbai

ITA 4594/MUM/2024[2015-16]Status: DisposedITAT Mumbai18 Dec 2024AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mrs. Suby Srivastava

Section 132Section 142(1)Section 143(2)Section 144Section 148Section 68

truly all material facts necessary for its assessment so far as this amount is concerned. Therefore, this case is fit for issuing notice under Section 148 of the Income Tax Act, 1961. In this case the assessment was made under Section 143 (1) not under Section

Tungsten Network Limited, United Kingdom vs. Dy.Commissioner of Income Tax, Civic Centre, Minto Road

In the result, appeal filed by the assessee is dismissed

ITA 2238/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Dec 2024AY 2017-18

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishraita Nos. 2237 & 2238/Del/2024 (Assessment Years : 2016-17 & 2017-18) Tungsten Network Ltd. Vs. Dy. Cit Anil Saraf, No.8-2-350/3/C, Civic Centre, Road No.3, Banjara Hills, Minto Road, Hyderabad, Telangana-34 New Delhi – 110 002 Pan : Aajct 5973 F (Appellant) (Respondent) Assessee By Shri Anil Saraf, C.A. & Shri Anish Raj Saraf, C.A. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 25.11.2024 Date Of Pronouncement 18.12.2024 O R D E R Per Bench :

Section 142(1)Section 144Section 144C(5)Section 147Section 148Section 9(1)(vii)

India in the hands of the assessee. Notice dated 29.07.2022 under section 148 of the Act was issued. In response to notice under section 148 of the Act, assessee did not file return of income even after being allotted a PAN (AAJCT5973F). Notice under section 142(1) dated

Tungsten Network Limited, United Kingdom vs. Dy.Commissioner of Income Tax, Civic Centre, Minto Road

In the result, appeal filed by the assessee is dismissed

ITA 2237/DEL/2024[2016-17]Status: DisposedITAT Delhi18 Dec 2024AY 2016-17

Section 142(1)Section 144Section 144C(5)Section 147Section 148Section 9(1)(vii)

Vinay Aggarwal, Jind vs. Income Tax Officer, Income Tax Office, Jind

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

ITA 3487/DEL/2023[2013-14]Status: DisposedITAT Delhi18 Dec 2024AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarvinay Aggarwal Vs. Ito Kothi No.2145, Urban Urban Estate, Jind Estate, Jind, Haryana-02 Haryana-126 102 Pan : Aazpa 7517 R (Appellant) (Respondent) Assessee By Shri Sudhir Sahgal, Adv. Respondent By Ms. Harpreet Kaur Hansra, Sr. D.R. Date Of Hearing 18.12.2024 Date Of Pronouncement 18.12.2024 O R D E R Per Vimal Kumar, Jm:

Section 142(1)Section 147Section 148Section 151Section 288ASection 69ASection 69C

Bank, Delhi Branch) Total Rs.1,57,30,423/- 3. Approval from authorities under section 151 of the Act was obtained for issuance of notice under section 148 of the Act. Notice under section 148 of the Act dated 31.03.2021 was issued. Notice under section 142(1) dated 23.06.2021 was issued ... Ward-1, Jind. The assessee did not file return of income in response to notice under section 148 of the Act. Subsequently, the case was assigned to Faceless Assessment Unit under Faceless Assessment Scheme, 2019. In response to the notice, no reply was filed by the assessee. Notice under section

Amit Khatri, Sonipat vs. ITO, Ward 1, Sonipat

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

ITA 2430/DEL/2023[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.2430/Del/2023 िनधा"रणवष"/Assessment Year: 2012-13 बनाम Amit Khatri Income Tax Officer Ward No.30, Garhi Bhraman, Vs. Ward-1, Sonipat, Haryana. Sonipat, Haryana. Pan No. Bdspk3438G अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151

assessee is concerned, the assessee has challenged the validity of the reassessment proceeding on the ground that approval for issue of the notice under section 148 of the Act was granted by the LearnedPr.CIT in a mechanical manner and without application of mind and, therefore, reassessment proceeding must be quashed

Gac Marine Llc, Gurgaon vs. ITO, Ward 1(3)(2), International Taxation, New Delhi

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

ITA 2018/DEL/2023[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: Shri Vimal Kumar & Shri Avdhesh Kumar Mishragac Marine Llc Vs. Ito, Ward – 1(3)(2), 1St Floor, Ahip Palms, International Taxation, Plot No.242 & 243, New Delhi – 110 002 Phase-Iv, Gurgaon Haryana – 122 015 Pan : Aaecg 2882 R (Appellant) (Respondent) Assessee By Shri Gaurav Singhal, Adv. & Ms. Mahima Jain, Adv. Respondent By Shri Vijay B. Vasanta, Cit-D.R. Date Of Hearing 28/11/2024 Date Of Pronouncement 18/12/2024 O R D E R Per Vimal Kumar, Jm:

Section 142(1)Section 144Section 147Section 148Section 195Section 90(2)

filing of return of income. No response was filed. Learned AO recorded reasons under section 147 of the Act and issued notice under section 148 of the Act. No compliance was made by the assessee. Learned AO issued notice under section 142(1) of the Act on 08.11.2019 & 14.11.2019 seeking

The Abhinandan Co-Operative Group Housing Society Limited, Gurgaon vs. ITO Ward-4(4), Gurgaon

In the result, appeal filed by the assessee is partly allowed

ITA 1850/DEL/2023[2011-12]Status: DisposedITAT Delhi18 Dec 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Vimal Kumarthe Abhinandan Co- Vs. Income Tax Office Operative Group Housing Ward – 4(4) Society Limited Gurgaon Plot No.Gh-8, Sector – 51, Gurgaon, Haryana – 18 Pan : Aabat 5987 D (Appellant) (Respondent) Assessee By Shri Suraj Bhan Nain, Adv. & Shri Mahfuzur Rehman, C.A. Respondent By Shri Amit Katoch, Sr. D.R. Date Of Hearing 09.10.2024 Date Of Pronouncement 18.12.2024 O R D E R Per Vimal Kumar, Jm:

Section 142Section 143(3)Section 147Section 148Section 69A

Central Co-op Bank. By recording reasons, the case was reopened after obtaining the necessary approval from PCIT, Gurgaon vide letter No.F.N.CIT/GGN/TECH/2017-18/7185. Notice under section 148 of the Act was issued on 22.03.2018. In response to notice, assessee submitted reply on 22.10.2018 and furnished ITR for the year ... declaring income at Rs.1,81,140/- from other sources in response to notice under section 148 of the Act and requested reasons for reopening under section 148 of the Act. Reasons for reopening the case and notice under section 142 was sent on 20.11.2018. Assessee filed reply and furnished

Trident Sales Corporation, Gurgaon vs. ITO Ward - 3(4), Gurgaon

Appeal of the assessee is allowed

ITA 70/DEL/2021[2010-11]Status: DisposedITAT Delhi18 Dec 2024AY 2010-11

Bench: SHRI VIKAS AWASTHY (Judicial Member)

For Appellant: Shri Lalit Mohan, Chartered AccountantFor Respondent: Shri Sanjay Tripathi, Sr. DR

Section 147Section 148Section 5

grounds raised by the assessee in appeal (including additional grounds raising legal issues) are as under:- “1. That in absence of any valid notice under section 148 of the Act having been issued and served on the appellant prior to framing of impugned order of 4 assessment, impugned order

Phool Singh, Haryana vs. ITO Ward-3(2), Gurgaon

In the result, appeal of the assessee is allowed

ITA 1986/DEL/2019[2013-14]Status: DisposedITAT Delhi18 Dec 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Vimal Kumarphool Singh Vs. Ito Plot No.2394 (Basement), Ward – 3(2) Sector – 46, Gurgaon Gurgaon, Haryana – 122 002 Pan : Eurps 4895 E (Appellant) (Respondent) Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Agarwal, Adv. Respondent By Shri Rajesh Dhanesta, Sr. D.R. Date Of Hearing 08.10.2024 Date Of Pronouncement 18.12.2024 O R D E R Per Vimal Kumar, Jm:

Section 143Section 143(2)Section 147Section 148Section 54BSection 54F

were initiated after recording the reasons, in writing and taking necessary approval from the Joint Commissioner of Income Tax, Range-3, Gurgaon. Notice under section 148 of the Act for A.Y. 2013-14 was issued on 24.01.2017. In compliance with the notice, assessee filed return of income on 29.06.2017 declaring ... under section 54B of the Act amounting to Rs.3,08,33,650/-. On receiving the Income-tax Return, in response to the notice under section 148 of the Act, notice under section 143(2) of the Act was issued on 07.07.2017. Copy of reasons were provided to assessee vide order

ACIT, Central Circle- 30, New Delhi vs. Rajnil Sales Pvt. Ltd., New Delhi

ITA 4050/DEL/2017[2012-13]Status: DisposedITAT Delhi18 Dec 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2012-13 Acit, Vs Rajnil Sales Pvt. Ltd., Room No.91, 4Th Floor, Central Circle-30, New Delhi. 2B Grant Lane, Kolkata, West Bengal. Pan: Aabcr3491C (Appellant) (Respondent) Assessee By : Shri Ajay Wadhwa, Advocate & Ms Ragini Handa, Advocate Revenue By : Shri Pitambar Das, Cit-Dr Date Of Hearing : 25.11.2024 Date Of Pronouncement : 18.12.2024 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 31.03.2017 Of The Commissioner Of Income Tax (Appeals)-30, New Delhi (Hereinafter Referred As Ld. First Appellate Authority Or In Short Ld. ‘Faa’) In Appeal No.320/15-16/2297 Arising Out Of The Appeal Before It Against The Order Dated 31.03.2015 Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Acit, Central Circle-30, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Ajay Wadhwa, Advocate &For Respondent: Shri Pitambar Das, CIT-DR

Section 127Section 143(2)Section 143(3)Section 68

August, 1976, and the income of the assessment year 1969-70 could be assessed by issuing a notice by March 31, 1978. Notice under section 148 was issued on March 23, 1978, and the Income Tax Officer was naturally anxious to see that the notice gets served by March

Ethix Healthcare, Chandigarh vs. Deputy Commissioner of Income Tax, Circle, Parwanoo

In the result, both on the exercise of jurisdiction u/s 147 and on merits of the case, the order of the AO as well as the ld CIT(A) is hereby set-aside and matter is decided in favour of the assessee

ITA 501/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh17 Dec 2024AY 2012-13

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

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri VivekVardhan, JCIT, Sr. DR

Section 139Section 143(3)Section 147Section 148Section 250Section 80Section 80I

account of endorsement and packing charges. Thereafter, proceedings under section 147 were initiated after recording the reasons and issuance of notice under section 148 dt. 22/07/2016 and the reasons so recorded reads as under: “The assessee firm filed its return of income for the asstt year 2012-13 declaring income ... escaped assessment under section 147 of the Income Tax Act, 1961 for the A.Y. 2012-13.” 4. In response to the notice under section 148, the assessee submitted that return filed earlier under section 139 may be taken as due compliance to the notice under section 148. Thereafter, after supplying

Income-Tax Officer, Ward-1(3)(1), Ahmedabad vs. Deval Pranav Patel L/H. of Late Shri Pranav Mahendrabhai Patel, Ahmedabad

In the result, appeal of the Revenue is dismissed

ITA 182/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad17 Dec 2024AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year: 2017-18

Section 10(38)Section 115BSection 142(1)Section 143(2)Section 148Section 68Section 69C

Rs.7,57,24,817/- during the year under consideration as per the observation of the Assessing Officer. The reasons were recorded and notice under Section 148 of the Income Tax Act, 1961 dated 21.04.2021 was issued to the assessee calling for return of income for Assessment Year

Gunvantbhai Narandas Patel, Ahmedabad vs. The Income Tax Officer, Ward-2, Gandhinagar

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

ITA 1459/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad17 Dec 2024AY 2013-14

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year: 2013-14

Section 143(2)Section 147Section 148Section 2(14)Section 68

After recording the reasons to believe, the proceedings under Section 147 of the Income Tax Act, 1961 was initiated after approval. Notice under Section 148 of the Act was issued to the assessee on 28.03.2019. The assessee filed his return of income in response to the notice under Section 148