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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

Jasdev Singh, Bathinda vs. ITO, Ward 1(1), Btd, Bathinda

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

ITA 662/ASR/2024[2012-13]Status: DisposedITAT Amritsar09 Feb 2026AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 662/Asr/2024 Assessment Year: 2012-13 Jasdev Singh, Vs. Ito, Ward 1(1), Gobindpura, Bathinda. Bathinda. [Pan:-Bzyps0363N] (Appellant) (Respondent) Sh. Rohit Kapoor, Adv & Sh. V.S. Appellant By Aggarwal, Itp Respondent By Sh. Charan Dass, Sr. Dr

Section 139Section 143(3)Section 148Section 151Section 250

under appeal consideration 2) Information was available to department that Appellant had deposited large amount of cash in the bank account 3) Notice under section 148 was issued after taking statutory permission under section 151 4) Notice was issued for filing of return and AA finally filed ROI in response

M/S. Shreedhar Construction, Jamnagar vs. The ITO Ward- 1 (3) Jamnagar, Jamnagar

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

ITA 542/RJT/2025[2014-15]Status: DisposedITAT Rajkot09 Feb 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 542/Rjt/2025 (Assessment Year: 2014-15) (Hybrid Hearing) M/S. Shreedhar Construction, The Ito, Vs. 211, Divyam Complex Airodrome Ward-1(3), Road,Jamnagar-361006 ( Gujarat) Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclfs0395R (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Ahimanyu Singh Yadav, Sr. DR
Section 143(2)Section 147Section 148Section 148ASection 151Section 234ASection 271(1)(b)

Before, learned CIT(A), the assessee has raised the technical grounds stating that reassessment proceedings initiated by the assessing officer and notice under section 148 of the Act, issued by the assessing officer, are bad in law. The assessee has also raised the technical ground before the learned ... that notice under section 148 of the Act is barred by limitation, therefore, assessment proceedings should be quashed. The assessee also raised the ground before the learned CIT(A) that assessment was reopened beyond a period of three years from the end of the relevant assessment year without proper approval

Jivanbhai De vs. Hibhai Sarla, Thangadh, Dist. Surendranagarvs.the ITO Ward 2, Surendranagar

ITA 521/RJT/2025[2014-15]Status: DisposedITAT Rajkot09 Feb 2026AY 2014-15

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

For Appellant: Ms. Devina Patel, ARFor Respondent: Shri Sanjay Punglia, CIT-DR &
Section 147Section 250Section 271(1)(c)

with TOLA will be available to the Revenue to complete the remaining proceedings in furtherance of the deemed notices, including issuance of reassessment notices under section 148 of the new regime. The surviving or balance time limit can be calculated by computing the number of days between the date ... 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 started ticking, the assessing officer was required to complete these procedures within

Jivanbhai De vs. Hibhai Sarla, Thangadh, Dist. Surendranagarvs.the ITO Ward-2, Surendranagar

ITA 519/RJT/2025[2013-14]Status: DisposedITAT Rajkot09 Feb 2026AY 2013-14

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

For Appellant: Ms. Devina Patel, ARFor Respondent: Shri Sanjay Punglia, CIT-DR &
Section 147Section 250Section 271(1)(c)

with TOLA will be available to the Revenue to complete the remaining proceedings in furtherance of the deemed notices, including issuance of reassessment notices under section 148 of the new regime. The surviving or balance time limit can be calculated by computing the number of days between the date ... 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 started ticking, the assessing officer was required to complete these procedures within

Kunkulagunta Mallikarjuna Rao, Vijayawada vs. Income Tax Officer, Ward-2(1), Vijayawada

Accordingly, finding no infirmity in the view of the CIT(A), who, in my view, in the absence of any plausible explanation of the assessee regarding the delay involved in filing of the appeal, had r...

ITA 579/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam09 Feb 2026AY 2019-20

Bench: Shri Ravish Sood, Hon’Ble

Section 144Section 147Section 148Section 148ASection 68Section 69

then ITO, Ward-2(1), Vijayawada on 28.02.2023. Thereafter, the AO passed an order under section 148A(d) of the Act dated 30.03.2023. Notice under section 148 of the Act dated 30.03.2023 was thereafter issued by the ITO, Ward-2(1), Vijayawada. 3. During the course of the assessment proceedings

Vatadi Krishnarao, Palakole vs. ITO, Ward - 1, Palakole

ITA 528/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam09 Feb 2026AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble

Section 147Section 148Section 148ASection 151ASection 250

reply, therefore, the AO, with the approval of the competent authority passed an order under section 148A(d) of the Act, dated 12.03.2024. Notice under section 148 of the Act, dated 26.03.2024, was thereafter issued by the A.O., but the assessee failed to file his return of income in compliance

Abhimanyu Gupta, Patiala vs. Dy. Commissioner of Income Tax, Circle-Patiala, Patiala

In the result, the appeal of the assessee is allowed

ITA 979/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh09 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 115BSection 144BSection 147Section 148Section 153CSection 69

evidence being relied upon was found from the premises of the searched person and as such upholding of the issuance of notice under section 148 as against Section 153C is illegal, arbitrary and unjustified. 6. Without prejudice to the above, the Ld. Commissioner of Income Tax (Appeals) has further erred ... addition under section 69 can be sustained on the basis of third-party digital material and statements. 8.1 We note that the notice under section 148 was issued by the Jurisdictional Assessing Officer and not by the National Faceless Assessment Centre through automated allocation, as mandated under section 151A read

DCIT, CC-3, Ludhiana, Kitchlu Nagar vs. Mani Ram Balwant Rai HUF, Civil Lines

The appeal of the Revenue is dismissed

ITA 1043/CHANDI/2024[2022-23]Status: DisposedITAT Chandigarh09 Feb 2026AY 2022-23

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Smt. Geetinder Mann, CIT DR
Section 127Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 144BSection 145(3)Section 28Section 69C

material, the failure to comply with that requirement renders the assessment legally untenable.28. In the present case, the AO did not issue a notice under section 148, nor did he follow the due process of law under the new reassessment framework, including recording of satisfaction and obtaining prior sanction from

Hasmukh Ugarchand Gadhecha, HUF, Ahmedabad vs. The ITO, Ward-5(2)(2), Ahmedabad

The appeal of the assessee stands allowed

ITA 591/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.591/Ahd/2025 िनधा"रण वष" /Assessment Year : 2013-14 Hasmukh Ugarchand The Ito बनाम/ Gadhecha, Huf Ward-5(2)(2) V/S. 3Rd Floor, Anjalee House Ahmedabad – 380 015 Cg Road Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaahg 7194 K (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/11/2025 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 26/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2013-2014. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Hasmukh Ugarchand Gadhecha, Huf Vs. Ito Asstt.Year : 2013-14 2 “1. That The Ld.Cit(A) Erred In Law & In The Facts Of The Case In Confirming The Order Of The Ao In Reopening Assessment U/S.147 Of The Act.

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Hargovind Singh, Sr.DR
Section 10(38)Section 143(3)Section 147Section 148Section 153CSection 250Section 68Section 69C

assumption of jurisdiction by the AO in this case under section 147 of the Act was invalid and without jurisdiction. Accordingly, the notice under section 148 and the subsequent reassessment order are quashed. 8.7. Since we have quashed the assessment order on the legal ground, therefore, the issues raised

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1268/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

this case, more than four years have lapsed from the end of assessment year under consideration. Hence necessary sanction to issue notice under section 148 of the Income Tax Act, 1961 has been obtained separately from the Principal Commissioner of Income Tax-3, Ahmedabad as per the provisions of section ... this case, more than four years have lapsed from the end of assessment year under consideration. Hence necessary sanction to issue notice under section 148 of the Income Tax Act, 1961 has been obtained separately from the Principal Commissioner of Income Tax-3, Ahmedabad as per the provisions of section

Income Tax Officer Ward 7.2.1 Ahmedabad, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1267/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

this case, more than four years have lapsed from the end of assessment year under consideration. Hence necessary sanction to issue notice under section 148 of the Income Tax Act, 1961 has been obtained separately from the Principal Commissioner of Income Tax-3, Ahmedabad as per the provisions of section ... this case, more than four years have lapsed from the end of assessment year under consideration. Hence necessary sanction to issue notice under section 148 of the Income Tax Act, 1961 has been obtained separately from the Principal Commissioner of Income Tax-3, Ahmedabad as per the provisions of section

Income Tax Officer, Ward 7.2.1, Ahmedabad vs. Raghavbhai Gordhanbhai Narola, Ahmedabad

Appeals of the Revenue are hereby dismissed, whereas, all the Cross Objections filed by the assessee are hereby allowed

ITA 1266/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Hargovind Sinh, Sr.DR
Section 143(1)(a)Section 148Section 250

this case, more than four years have lapsed from the end of assessment year under consideration. Hence necessary sanction to issue notice under section 148 of the Income Tax Act, 1961 has been obtained separately from the Principal Commissioner of Income Tax-3, Ahmedabad as per the provisions of section ... this case, more than four years have lapsed from the end of assessment year under consideration. Hence necessary sanction to issue notice under section 148 of the Income Tax Act, 1961 has been obtained separately from the Principal Commissioner of Income Tax-3, Ahmedabad as per the provisions of section

Incometax Officer, Ward-1, Ballari vs. Bellary Urban Development Authority, Ballari

ITA 1523/BANG/2025[2015]Status: DisposedITAT Bangalore09 Feb 2026

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Ajith V, AdvocateFor Respondent: Shri Balusamy .N, JCIT-DR
Section 10(46)Section 139(1)Section 142(1)Section 143(2)Section 148Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K

Essa Shaikh, Mumbai vs. ITO Ward 17(1)(1), Mumbai

ITA 8266/MUM/2025[2018-19]Status: HeardITAT Mumbai09 Feb 2026AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethessa Shaikh, Vs. Ito Ward 17(1)(1), 106, Kautilya Bhavan, 3Rd Floor, Room No. 29, Ismail C-41 To C-43, G Block, Bkc, Bandra (East), Dossa Building, 117 Shaida Mumbai-400051. Marg, Mumbai-400009. Pan/Gir No: Cdgps7700A (Appellant) (Respondent) Appellant By Shri Gaurang Khakhkhar (Virtually Present) Respondent By Shri Aditya Rai (Sr Dr) Date Of Hearing 09.02.2026 Date Of Pronouncement 09.03.2026 O R D E R Per Bijyananda Pruseth, Am:

Section 147Section 148Section 151Section 250Section 44A

entire reassessment proceedings void ab initio. 8. That as per sub section I of section 151, in cases WHARE the reopening notice under section 148 is issued after the expiry of 8 three years from the end of the relevant assessment year, prior sanction of the PCCIT is mandatory ... approval of PCIT does not satisfy the statutory requirement. 9. That the impugned notice under section 148 having been issued by a Jurisdictionally Assessing Officer JAO and not by the Faceless Assessing Officer FAO is void ab initio and without legal sanction. 10. That the learned Assessing Officer has erred

Rakesh Jain As the Legal Heir of Bhawarlal Shrilal Jain, Mumbai vs. ITO Ward-1 Palghar, Mumbai

In the result, all four appeals of the assessee stand allowed

ITA 7677/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

total deposits considered were Rs. 1,67,77,000/-.On the basis of such information, proceedings under section 147 were initiated. Notice under section 148 dated 17.03.2020 was issued after recording reasons and obtaining sanction under section 151.Since no return was filed in response to notice under section 148 ... appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired on 17.09.2010.The appellant also argued that the notice under section 148 dated 17.03.2020 was issued in the name of a deceased person and proceedings were continued and assessment was completed in the name

Rakesh Jain As the Legal Heir of Bhawarlal Shrilal Jain, Mumbai vs. ITO Ward -1 Palghar, Thane

In the result, all four appeals of the assessee stand allowed

ITA 7676/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

total deposits considered were Rs. 1,67,77,000/-.On the basis of such information, proceedings under section 147 were initiated. Notice under section 148 dated 17.03.2020 was issued after recording reasons and obtaining sanction under section 151.Since no return was filed in response to notice under section 148 ... appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired on 17.09.2010.The appellant also argued that the notice under section 148 dated 17.03.2020 was issued in the name of a deceased person and proceedings were continued and assessment was completed in the name

Rakesh Jain As the Legal Heir of Bhawarlal Shrilal Jain, Mumbai vs. ITO Ward 1 Palghar, Thane

In the result, all four appeals of the assessee stand allowed

ITA 7675/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

total deposits considered were Rs. 1,67,77,000/-.On the basis of such information, proceedings under section 147 were initiated. Notice under section 148 dated 17.03.2020 was issued after recording reasons and obtaining sanction under section 151.Since no return was filed in response to notice under section 148 ... appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired on 17.09.2010.The appellant also argued that the notice under section 148 dated 17.03.2020 was issued in the name of a deceased person and proceedings were continued and assessment was completed in the name

Rakesh Jain As the Legal Heir of Bhawarlal Shrilal Jain, Mumbai vs. ITO Ward 1, Palghar, Thane

In the result, all four appeals of the assessee stand allowed

ITA 7674/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

Section 142(1)Section 144Section 147Section 148Section 151Section 159Section 271FSection 69A

total deposits considered were Rs. 1,67,77,000/-.On the basis of such information, proceedings under section 147 were initiated. Notice under section 148 dated 17.03.2020 was issued after recording reasons and obtaining sanction under section 151.Since no return was filed in response to notice under section 148 ... appellant, being legal heir Shri Rakesh Jain, contended that Late Shri Bhawarlal Shrilal Jain expired on 17.09.2010.The appellant also argued that the notice under section 148 dated 17.03.2020 was issued in the name of a deceased person and proceedings were continued and assessment was completed in the name

Nova Elevators Private Limited, Mumbai vs. ITO-13(1)(1), Mumbai

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

ITA 7248/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarnova Elevators Private Vs Ito -13(1)(1), Mumbai Limited Maharashtra-400020 402, Dimple Apts., 4E, Asha Nagar, Kandivali East, Mumbai-400101 Pan: Aadcn0305K Appellant Respondent Assessee By : Shri Sharad Patel, Ca Respondent By : Shri Leyaqat Ali Aafaqui, (Sr Ar) Date Of Hearing : 29/01/2026 Date Of Pronouncement : 09/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-51, Mumbai [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2014-15, Date Of Order 12.09.2025. The Impugned Order Emanated From The Order Of The Ld. Income-Tax Officer Ward-13(1)(1), Mumbai

For Appellant: Shri Sharad Patel, CAFor Respondent: Shri Leyaqat Ali Aafaqui, (SR AR)
Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

assessee's own transactions and factual records. b. The reasons recorded for reopening were not furnished at the time of issuance of notice under section 148 and were supplied only at the fag end of the assessment proceedings, thereby denying the assessee a fair and reasonable opportunity to raise objections ... available on record. The assessee had filed the original return of income declaring nil income. Subsequently, the assessment was reopened by issuance of notice under section 148 of the Act. In the reassessment proceedings, the Ld. AO made an addition of Rs.53,00,000/- on account of unexplained cash credits

K M Textiles Export Private Limited, Mumbai vs. Income Tax Officer Ward 10(1)(1), Mumbai

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

ITA 6750/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Feb 2026AY 2017-18

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

Section 143(3)Section 147Section 148Section 69C

income chargeable to tax had escaped assessment, inter alia, on account of alleged bogus purchases and cash deposits during the demonetisation period. Accordingly, notice under section 148 was issued on 31.03.2024. 4. During the reassessment proceedings, the Assessing Officer noticed that cash aggregating to ₹16,10,995/- had been deposited