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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

Impressive Trading Private Limited, Mumbai vs. Income Tax Officer 10(1)(1), Mumbai

In the result, all the above appeals in ITA Nos

ITA 7299/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Feb 2026AY 2014-15

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)
Section 147Section 147oSection 148Section 148ASection 151A

consequential notice of demand and the penalty show cause notice. The Petitioner, without prejudice to the above challenge, also challenges, inter alia, the notice under Section 148 dated 25.07.2022 issued by Respondent No.1 seeking to reopen the Petitioner’s assessment for the A.Y.2014-15 and the order disposing of the objections ... absence of any reply of the Petitioner, Respondent No.1 stated that it is a fit case to issue notice under Section 148 of the Act. Simultaneously, a notice under Section 148 of the Act has been issued dated 25.07.2022, requiring the Petitioner to file his Return of Income within

Impressive Trading Pvt. Ltd., Mumbai vs. Income Tax Officer 10(1)(1), Mumbai

ITA 7298/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Feb 2026AY 2013-14
Section 147Section 148Section 148ASection 151A

consequential notice of demand and the penalty show cause notice. The Petitioner, without prejudice to the above challenge, also challenges, inter alia, the notice under Section 148 dated 25.07.2022 issued by Respondent No.1 seeking to reopen the Petitioner's assessment for the A.Y.2014-15 and the order disposing of the objections

Nisha Rajendra Mavani Legal Heir of Navnit Dharamsi Parmani, Mumbai vs. Income Tax Officer 19(2)(4), Mumbai

In the result, ground No. 1 to 3 are allowed

ITA 6514/MUM/2025[2012-2013]Status: DisposedITAT Mumbai11 Feb 2026AY 2012-2013

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 147Section 148Section 234ASection 234BSection 254(1)Section 69B

basis of information that the assessee had purchased property for a total consideration of Rs. 1.20 Crore. The assessing officer (AO) issued notice under section 148 dated ITA 6514/Mum/2025 (AY 2012-13) NishaRajendraMavani Legal Heir of NavnitDharamsiParmani 27.03.2029. The AO in para-2 of his order recorded that neither return ... income in response to notice under section 148 was filed nor any response to such notice. We find that assessment was completed under section 144 read with section 147 of the Act on 06.12.2016. On careful reading of assessment order, we find that there is no reference of any other

M/S. Sai Medisoultion Private Limited, Mumbai vs. ITO Circle -3, Thane

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

ITA 4716/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Feb 2026AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 69A

bank accounts of the assessee-company. Based on this information, the assessee’s case was reopened and notice under section 148 was issued on 31/03/2021. 4. During the reassessment proceedings, notices under section 142(1) dated 18/11/2021 were issued calling for various details, the particulars of which are incorporated

K & S Fincon Pvt Ltd, Aligarh vs. ITO Ward 14(1), Delhi

In the result the appeal of the assessee is allowed

ITA 6556/DEL/2025[2013-14]Status: DisposedITAT Delhi11 Feb 2026AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2013-14

Section 131Section 143(1)Section 143(3)Section 147Section 148Section 148ASection 149

take a decision under section 149A(d ) based on the available material and the reply of the assessee; and (iii) issue a notice under section 148 if it was a fit case for reassessment. Once the clock 4 started ticking, the assessing officer was see State ... surviving time limit, as prescribed under the Income Tax Act read with TOLA, was available to the assessing officers to issue the reassessment notices under section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under the old regime

Nileshkumar M Bhalodi, Rajkot vs. The Income Tax Officer, Ward - 2(1)(1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 7/RJT/2026[2015-16]Status: DisposedITAT Rajkot10 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Ms Devina Patel, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 250

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; Page 5 of 8 ITA No.7/Rjt/2026/AY 2015-16 Nileshkumar M. Bhalodi d. TOLA does not extend ... 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

Sanjaykumar Haribhai Parsana, Rajkot vs. DCIT/ACIT Cir 1(1), RKT, Rajkot

In the result, appeal filed by the assessee is allowed

ITA 596/RJT/2025[2015-16]Status: DisposedITAT Rajkot10 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Rajendra Singhal, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 147Section 148Section 148ASection 149(1)(a)Section 250Section 69

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

Kuldip Singh, Ranchi vs. DCIT/ACIT, Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 180/RAN/2025[14-15]Status: DisposedITAT Ranchi10 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.180/Ran/2025 Assessment Year: 2014-15 Kuldip Singh…………………….……….……...................……….……Appellant The Avenue Vishnupuri Marg, Upper Burdwan Compound, Lalpur, Ranchi- 834001. [Pan: Agjps6921P] Vs. Dcit/Acit, Circle-1, Ranchi…...…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 10, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 06.03.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 56(2)(vii)

section 143(3) of the Income-tax Act, 1961, vide order dated 15.12.2016, accepting the returned income. Subsequently, the Assessing Officer issued a notice under section 148 of I.T.A. No.180/Ran/2025 the Act dated 22.11.2019, i.e., after the expiry of four years from the end of the relevant assessment year. Pursuant ... Representative (AR) submitted that in present case of the assessee the original assessment was completed under section 143(3) after full verification. The notice under section 148 dated 22.11.2019 was issued beyond four years from the end of AY 2014–15 and the reasons recorded while issuing notice

Manoharmal, Vijayawada vs. ITO, Ward-2(1), Vijayawada

ITA 619/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam10 Feb 2026AY 2013-14

Bench: Shri Ravish Sood, Hon’Ble

Section 115BSection 133(6)Section 147Section 148Section 68

assessee was reopened under section 147 of the Act on the ground of “Cash gift received from the daughter to purchase a property”. Notice under section 148 of the Act, dated 19.03.2021, was issued and duly served upon the assessee. In Page. No 2 I.T.A.No.619/VIZ/2025 Manoharmal compliance, the assessee

Palanisamy Shankarganesh, Erode vs. ITO Ward 1, (1), Erode

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

ITA 3544/CHNY/2025[2018-19]Status: DisposedITAT Chennai10 Feb 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./Ita No.: 3544/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Shri Palanisamy Shankarganesh The Income Tax Officer, Prop: Universal Communication, Vs. Ward-1(1), No.56, Mettur Road, Erode, Erode. Tamil Nadu-638 001. [Pan: Azsps4331D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr.Bhupendran, Advocate ""यथ" क" ओर से/Respondent By : Mr.Sbr Kumar Laghimsetti, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 20.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 10.02.2026

For Appellant: Mr.Bhupendran, AdvocateFor Respondent: Mr.SBR Kumar Laghimsetti
Section 142(1)Section 143(1)Section 147Section 148Section 148ASection 151

Company (supra) reads as follows:- “9. A perusal of Section 151(i) would show that, the specified authority for the purpose of issuing notice under Section 148 within a period of three years from the end of the relevant assessment year is, the Principal Commissioner or Principal Director or Commissioner ... approval was obtained before issuance of 148 notice in terms of provision of Section 151(ii), which is mandatory. Therefore, the notice under Section 148 was issued in the present case in violation of provision of Section 151(ii) of the Income Tax Act. In view thereof, the initiation

Mrs. Jeanette Dsouza Legal Representative of Late Shri. Vinod Dsouza), Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, with above direction to the learned assessing officer, the ground No

ITA 2348/BANG/2025[2016-17]Status: DisposedITAT Bangalore10 Feb 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2016-17 Mrs. Jeanette Dsouza, Lr Of Late Shri Vinod Dsouza, Flat No. San F 10, The Income Tax Officer, Holy Family Apartments, Ward – 1(1), Vs. Lalbagh, Mangalore, Mangalore. Karnataka – 575 003. Pan: Adhpd4076H Appellant Respondent

For Appellant: Shri Prasanna Shenoy, CA
Section 139Section 142Section 144Section 144BSection 147Section 148Section 148ASection 149Section 159Section 55

appeal of the assessee. Therefore, the assessee is in appeal before us. 7. The learned authorized representative submitted that that the notice under section 148 was issued on 22 June 2021 which was later treated as a show cause notice under section 148A (b) following the decision of the honourable ... grant such benefit despite having the copy of the sale deed available with them. In the end the assessee submitted that that notice under section 148 was issued on 29th of March 2021 in the name of Sri Vinod D'Souza. The assessee passed away on 17 April 2021. Despite

Mr. Saurabh Anil Gandhi, Mumbai vs. Income Tax Officer Ward 42(3)(3), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 8437/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Feb 2026AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailmr. Saurabh Anil Gandhi A-502 Chanakya Chs Ltd. Mahavir Nagar, Opp. Ekta Nagar, New Link Road, Kandivali West, Mumbai- 400067 ............... Appellant Pan: Aelpg7302J

For Appellant: Shri Nikhil Tiwari a/wFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 132Section 147Section 148Section 153CSection 250Section 35Section 80Section 80G

donations received in cheque were returned in cash to all the donors after deducting normal commission, notice under section 148 of the Act was issued to the assessee on 28/03/2016. Accordingly, the proceedings under section 147 of the Act were initiated. In response to the notice, the assessee requested

Jignesh Janu Abgul, Thane vs. Income Tax Officer, WD-4(1), Thane

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

ITA 8083/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Feb 2026AY 2016-17

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Prakash Jhunjhunwala, CA & Shri Saiprasad GhoshFor Respondent: Ms. Kavita Kaushik (SR DR)
Section 147Section 148Section 151Section 250

section 148 of the Act to be invalid and has quashed the same. In view of the principles of judicial discipline, the said notice under section 148 stands quashed, and the order of the Hon’ble High Court is binding on the Ld. CIT(A) as well as on this ... Tribunal. Since the Ld. AO did not validly assume jurisdiction for issuance of notice under section 148 of the Act for the impugned assessment year, the assessment order itself is invalid and is hereby quashed. Consequently, the impugned appellate order also loses its validity. 4 Jignesh Janu Abgul Accordingly

Devanshi Sharma, Mumbai vs. ITO Ward 34(1)(1), Mumbai

In the result, the appeal is allowed as indicated above

ITA 7007/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardevanshi Sharma Ito, Ward 34(1)(1) 216, 2Nd Floor, Kautaliya Bhawan, Sagar Jyoti, Plot No. 18, Vs. 6Th Road, Jvpd Scheme, G-Block, Bandra Kurla Complex, Vile Parle (W), Mumbai-400 056 Bandra (E), Mumbai-400 051 Pan/Gir No. Cmvpk 6007 Q (Appellant) : (Respondent) Appellant By : Shri Shashank Mehta Respondent By : Shri Annavaram Kosuri Date Of Hearing : 05.02.2026 Date Of Pronouncement : 10.02.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against Order Dated 27.10.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2017-18. 2. In Ground No. 1, The Assessee Has Raised A Pertinent Legal Issue, Challenging The Validity Of The Order Passed U/S. 148A(D) Of The Income Tax Act, 1961 (‘The Act’ For Short) As Also The Notice Issued U/S. 148 Of The Act. Since, The Aforesaid Issue Raised By The Assessee Is A Purely Legal & Jurisdictional Issue Going To The Root Of The Matter & Affecting The Validity Of The Proceedings Initiated U/S. 147 Of The Act, We Are Inclined To Address The Issue At The Very Outset.

For Appellant: Shri Shashank MehtaFor Respondent: Shri Annavaram Kosuri
Section 10(38)Section 147Section 148Section 148ASection 151

assessments. The provision imposes a responsibility on the Revenue to ensure that it obtains the sanction of the specified authority before issuing a notice under section 148. The purpose behind this procedural check is to save the assessees from harassment resulting from the mechanical reopening of assessments. (Sri Krishna ... year. Thus, non-compliance by the Assessing Officer with the strict time limits prescribed under section 151 affects their jurisdiction to issue a notice under section 148. 77. Parliament enacted Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 to ensure that the interests of the Revenue

Deputy Commissioner of Income Tax Central Circle - 5(3), Mumbai vs. Unify Texturisers Private Limited, Mumbai

ITA 5055/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawaldcit Central Circle-5(3), Vs Unify Texturisers Private Limited Mumbai 3Rd Floor, Astral Centre, Nm Joshi Kautilya Bhawan, Bandra Marg, Opp. Chinchpokli Railway Kurla Complex, Bandra (East) Station, Mumbai-400011 Mumbai 400051 Pan: Aaacu8565F Appellant Respondent C.O. No.241/Mum/2025 (Arising Out Of I.T.A. No.5055/Mum/2025 A.Y. :2017-18)

For Appellant: Shri Jay BhansaliFor Respondent: Ms. Kavita Kaushik (SR DR)
Section 139(1)Section 147Section 148Section 148ASection 151Section 151(1)Section 250

filed a paper book which is containing page 1 to 411 which has been placed on record. The Ld. AR contended that the notice under section 148 of the Act was issued on 29.06.2021. The Ld. AR raised a preliminary objection regarding the validity of the sanction granted under section ... issuance of notice under section 148 of the Act. He drew our attention to the notice issued under section 148 of the Act dated 29.06.2021 in paragraph 3 (in APB page-49), wherein the approval for issuance of the said notice was accorded by the Range 8(3), Mumbai

Kabel Metal Power Cables Ltd, Thane vs. Dy. Commissioner of Income Tax, Circle-5(2)(1), Mumbai

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

ITA 4789/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarita No.4789/Mum/2025 (Assessment Year: 2014-15)

For Appellant: Shri Prakash Jhujhunwala a/w Shri Saiprasad GhoshFor Respondent: Shri Ritesh Misra (CIT DR)
Section 139(1)Section 143(2)Section 147Section 148Section 250

Nagendra Prasad [2023] 156 taxmann.com 19 (Patna), wherein it was held that even where the return was filed belatedly in response to notice under section 148, issuance of notice under section 143(2) was mandatory and such requirement could not be waived. Similar view has been taken

Kabel Metal Power Cables Ltd, Thane vs. Dy. Commissioner of Income Tax, Circle-5(2)(1), Mumbai

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

ITA 4788/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Feb 2026AY 2013-14

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarita No.4789/Mum/2025 (Assessment Year: 2014-15)

For Appellant: Shri Prakash Jhujhunwala a/w Shri Saiprasad GhoshFor Respondent: Shri Ritesh Misra (CIT DR)
Section 139(1)Section 143(2)Section 147Section 148Section 250

Nagendra Prasad [2023] 156 taxmann.com 19 (Patna), wherein it was held that even where the return was filed belatedly in response to notice under section 148, issuance of notice under section 143(2) was mandatory and such requirement could not be waived. Similar view has been taken

Nagpal, Uttar Pradesh vs. ITO Ward -2 (5), Chandausi

ITA 179/DEL/2026[2018-19]Status: DisposedITAT Delhi10 Feb 2026AY 2018-19

Bench: Sh. Satbeer Singh Godara

For Appellant: Sh. V. Rajkumar, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

petitioner's case that the said notice is barred by limitation. 9. It is material to note that the original notice under Section 148 of the Act [deemed to be a show cause notice under Section 148A(b) of the Act in terms of the decision in the case ... Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 [TOLA]. Thus, the AO had two days to issue the notice under Section 148 of the Act after receiving the reply dated 08.06.2022 filed by the petitioner. Since the said period was less than seven days

Krishna, Delhi vs. ITO Ward 36(1), Delhi

Appeal is allowed in above terms

ITA 166/DEL/2026[2017-18]Status: DisposedITAT Delhi10 Feb 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 166/Del/2026 : Asstt. Year: 2017-18 Mrs. Krishna, Vs Income Tax Officer, G-2/57, Sector-11, Rohini, Ward-36(1), New Delhi-110085 New Delhi-110001 (Appellant) (Respondent) Pan No. Aijpd1120H Assessee By: Sh. Manish Kumar, Ca & Sh. Gaurav Bhujel, Ar Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082534866(1) Dated 12.11.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Manish Kumar, CA &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

petitioner’s case that the said notice is barred by limitation. 9. It is material to note that the original notice under Section 148 of the Act [deemed to be a show cause notice under Section 148A(b) of the Act in terms of the decision in the case ... Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 [TOLA]. Thus, the AO had two days to issue the notice under Section 148 of the Act after receiving the reply dated 08.06.2022 filed by the petitioner. Since the said period was less than seven days

Krishan Pal, Gurgaon vs. ITO, Ward 2(2)-Gurgaon, Gurgaon

Appeal is allowed

ITA 139/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 139/Del/2026 : Asstt. Year: 2014-15 Krishan Pal, Vs Income Tax Officer, C/O Ca M R Sahu, Ward-2(2), House No. 651, 1St Floor, Sector- Gurgaon, 10A, Near G. D. Goenka Public Haryana-22001 School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Asqpk6236J Assessee By: Sh. M. R. Sahu, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1068016367(1) Dated 27.08.2024, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 142(1)Section 147Section 148Section 151ASection 80C

Scheme.—For the purpose of this Scheme,— (a)assessment, reassessment or re-computation under section 147 of the Act, (b)issuance of notice under section 148 of the Act, shall be through automated allocation, in accordance with risk management strategy formulated by the Board as referred to in section 148