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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

Atul Shamji Bharani, Mumbai vs. DCIT CC- 4(1), Mumbai

Appeal are allowed

ITA 2023/MUM/2023[2011-12]Status: DisposedITAT Mumbai09 Aug 2024AY 2011-12

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Vinod Kumar BindalFor Respondent: Shri Ajay Chandra
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 151Section 153ASection 250Section 68Section 69C

search on another entity, therefore the AO was duty bound to initiate the proceedings under section 153C of the Act instead of issuing notice under section 148 of the Act, in view of the non- obstante clause in section 153C(1) of the Act. Accordingly, it was submitted that since ... amounting to Rs.1,85,86,267. Accordingly, on the basis of aforesaid information, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 29/03/2018. The reasons recorded by the AO, while reopening the assessment for the year under consideration

Atul Shamji Bharani, Mumbai vs. DCIT CC- 4(1), Mumbai

Appeal are allowed

ITA 2022/MUM/2023[2013-14]Status: DisposedITAT Mumbai09 Aug 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Shri Vinod Kumar BindalFor Respondent: Shri Ajay Chandra
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 151Section 153ASection 250Section 68Section 69C

search on another entity, therefore the AO was duty bound to initiate the proceedings under section 153C of the Act instead of issuing notice under section 148 of the Act, in view of the non- obstante clause in section 153C(1) of the Act. Accordingly, it was submitted that since ... amounting to Rs.1,85,86,267. Accordingly, on the basis of aforesaid information, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 29/03/2018. The reasons recorded by the AO, while reopening the assessment for the year under consideration

Charanjit Singh, New Delhi vs. ITO Ward - 45(3), New Delhi

In the result, all the appeals of the assessee are allowed

ITA 5517/DEL/2019[2008-09]Status: DisposedITAT Delhi09 Aug 2024AY 2008-09

Bench: Before Shri Saktijit Dey, Hon’Ble Vice Before Before Shri Saktijit Dey, Hon’Ble Vice Shri Saktijit Dey, Hon’Bleshri Saktijit Dey, Hon’Ble & And & Shri M. Balaganesh Shri M. Balaganesh, Hon’Ble Accountant Shri M. Balaganesh Shri M. Balaganesh , Hon’Ble Accountant , Hon’Ble, Hon’Blemember Member

For Appellant: Shri G.S. Kohli, CAFor Respondent: Ms. Harpreet Kaur, Senior DR
Section 147Section 148Section 271(1)(c)Section 68

before expiry of six years from the end of the relevant assessment year. While deciding the issue, learned first appellate authority observed that notice under Section 148 was issued on 28th March, 2014 through speed post and the subsequent notice issued on 8th July, 2014 would not vitiate the assessment ... notice dated 28th March, 2014 referred to by the first appellate authority was never served on the assessee. He submitted that the only notice under Section 148 of the Act served on the assessee was notice dated 8th July, 2014. Thus, he submitted that the notice under Section 148, having

Charanjit Singh, New Delhi vs. ITO Ward - 45(3), New Delhi

In the result, all the appeals of the assessee are allowed

ITA 5516/DEL/2019[2007-08]Status: DisposedITAT Delhi09 Aug 2024AY 2007-08

Bench: Before Shri Saktijit Dey, Hon’Ble Vice Before Before Shri Saktijit Dey, Hon’Ble Vice Shri Saktijit Dey, Hon’Bleshri Saktijit Dey, Hon’Ble & And & Shri M. Balaganesh Shri M. Balaganesh, Hon’Ble Accountant Shri M. Balaganesh Shri M. Balaganesh , Hon’Ble Accountant , Hon’Ble, Hon’Blemember Member

For Appellant: Shri G.S. Kohli, CAFor Respondent: Ms. Harpreet Kaur, Senior DR
Section 147Section 148Section 271(1)(c)Section 68

before expiry of six years from the end of the relevant assessment year. While deciding the issue, learned first appellate authority observed that notice under Section 148 was issued on 28th March, 2014 through speed post and the subsequent notice issued on 8th July, 2014 would not vitiate the assessment ... notice dated 28th March, 2014 referred to by the first appellate authority was never served on the assessee. He submitted that the only notice under Section 148 of the Act served on the assessee was notice dated 8th July, 2014. Thus, he submitted that the notice under Section 148, having

Shri Charanjit Singh, New Delhi vs. ITO, Ward- 45(4), New Delhi

In the result, all the appeals of the assessee are allowed

ITA 4396/DEL/2016[2008-09]Status: DisposedITAT Delhi09 Aug 2024AY 2008-09

Bench: Before Shri Saktijit Dey, Hon’Ble Vice Before Before Shri Saktijit Dey, Hon’Ble Vice Shri Saktijit Dey, Hon’Bleshri Saktijit Dey, Hon’Ble & And & Shri M. Balaganesh Shri M. Balaganesh, Hon’Ble Accountant Shri M. Balaganesh Shri M. Balaganesh , Hon’Ble Accountant , Hon’Ble, Hon’Blemember Member

For Appellant: Shri G.S. Kohli, CAFor Respondent: Ms. Harpreet Kaur, Senior DR
Section 147Section 148Section 271(1)(c)Section 68

before expiry of six years from the end of the relevant assessment year. While deciding the issue, learned first appellate authority observed that notice under Section 148 was issued on 28th March, 2014 through speed post and the subsequent notice issued on 8th July, 2014 would not vitiate the assessment ... notice dated 28th March, 2014 referred to by the first appellate authority was never served on the assessee. He submitted that the only notice under Section 148 of the Act served on the assessee was notice dated 8th July, 2014. Thus, he submitted that the notice under Section 148, having

Shri Charanjit Singh, New Delhi vs. ITO, Ward- 45(4), New Delhi

In the result, all the appeals of the assessee are allowed

ITA 4395/DEL/2016[2007-08]Status: DisposedITAT Delhi09 Aug 2024AY 2007-08

Bench: Before Shri Saktijit Dey, Hon’Ble Vice Before Before Shri Saktijit Dey, Hon’Ble Vice Shri Saktijit Dey, Hon’Bleshri Saktijit Dey, Hon’Ble & And & Shri M. Balaganesh Shri M. Balaganesh, Hon’Ble Accountant Shri M. Balaganesh Shri M. Balaganesh , Hon’Ble Accountant , Hon’Ble, Hon’Blemember Member

For Appellant: Shri G.S. Kohli, CAFor Respondent: Ms. Harpreet Kaur, Senior DR
Section 147Section 148Section 271(1)(c)Section 68

before expiry of six years from the end of the relevant assessment year. While deciding the issue, learned first appellate authority observed that notice under Section 148 was issued on 28th March, 2014 through speed post and the subsequent notice issued on 8th July, 2014 would not vitiate the assessment ... notice dated 28th March, 2014 referred to by the first appellate authority was never served on the assessee. He submitted that the only notice under Section 148 of the Act served on the assessee was notice dated 8th July, 2014. Thus, he submitted that the notice under Section 148, having

Shree Gautam Labdhi Con Corp LLP, Ahmedabad vs. The ITO, Ward-1(1)(3), Ahmedabad

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

ITA 38/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad08 Aug 2024AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 142(1)Section 143(1)Section 143(2)Section 144BSection 147Section 148Section 68

taxed in the hands of the assessee. The order under Section 148(d) of the Act was passed on 24.03.2022 and then notice under Section 148 of the Act was issued in 24.01.2022. To verify the issue, notice under Section 142(1) dated 23.09.2022 was issued to the assessee ... Section 148 of the Act asking the assessee to file the return of income, the Ld. AR submitted that the requirement to issue notice under Section 148 is mandatory as per the Act and not a procedural one and non-issuance of the same and making assessment order is illegal

Lks Bullion (Import and Export) Pvt.Ltd., Ahmedabad vs. The Income Tax Officer, Ward-2(1)(3), Ahmedabad

In the result, the appeal by Assessee is partly allowed

ITA 382/AHD/2022[2010-11]Status: DisposedITAT Ahmedabad08 Aug 2024AY 2010-11

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.382/Ahd/2022 "नधा"रण वष" /Assessment Year : 2010-11 L.K.S. Bullion (Import & The Income Tax Officer बनाम/ Export) Pvt.Ltd. Ward-2(1)(3) 368, Lks House, Ahmedabad – 380 014 V/S. Khetarpal-Ni-Pole Manek Chowk Ahmedabad -380 001 (Gujarat) "थायी लेखा सं./Pan: Aaacl 7369 N अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar Revenue By : Shri Alpesh Parmar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 05/08/2024 घोषणा क" तार"ख /Date Of Pronouncement: 08/08/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Dated 27/08/2022 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Ld.Cit(A)” In Short] Arising Out Of The Assessment Order Dated 18/12/2017 By The Assessing Officer (Ao) Under Section 143(3) R.W.S. 147 Of The Income L.K.S. Bullion (Import & Export) Pvt.Ltd. Vs. Ito Asst. Year : 2010-11

For Appellant: Shri S.N. Soparkar, Sr.Advocate &For Respondent: Shri Alpesh Parmar, Sr.DR
Section 131Section 133(6)Section 143(1)Section 143(3)Section 148

1374/Del/2015), the Tribunal found that the AO did not possess adequate information or material evidence at the time of issuing the notice under Section 148. The decision to reopen was based on a list provided by the CIT (Central-II) without independent verification or application of mind

Deputy Commissioner of Income Tax, Central Circel-2(1), Nagpur vs. Shri Ramakant Govindrao Mendhe, Nagpur

In the result, appeal filed by the Revenue for the A

ITA 163/NAG/2023[2019-20]Status: DisposedITAT Nagpur08 Aug 2024AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 133ASection 142(1)Section 144Section 147Section 148Section 69ASection 69C

year under consideration, the assessee filed his original return of income on 24/07/2018, declaring total income of ` 3,18,980. In response to notice under section 148 of the Act, which was issued on 17/02/2021, the assessee did not comply it, hence notice under section

Deputy Commissioner of Income Tax, Central Circle-2(1), Nagpur vs. Shri Ramakant Govindrao Mendhe, Nagpur

In the result, appeal filed by the Revenue for the A

ITA 162/NAG/2023[2018-19]Status: DisposedITAT Nagpur08 Aug 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 133ASection 142(1)Section 144Section 147Section 148Section 69ASection 69C

year under consideration, the assessee filed his original return of income on 24/07/2018, declaring total income of ` 3,18,980. In response to notice under section 148 of the Act, which was issued on 17/02/2021, the assessee did not comply it, hence notice under section

Nagaruru Srinivasa Rao, Kurnool vs. ACIT., Circle-1, Kurnool

In the result, appeal of the assessee is allowed in the above terms

ITA 422/HYD/2023[2011-12]Status: DisposedITAT Hyderabad08 Aug 2024AY 2011-12

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.422/Hyd/2023 (निर्धारण वर्ा / Assessment Year: 2011-12)

For Appellant: B.Satyanarayana Murthy, ARFor Respondent: Ms. Sheetal Sarin, DR
Section 143(1)Section 148Section 69B

income of ₹ 2,78,840/-. It was processed under section 143(1) of the Income Tax Act, 1961 (for short “the Act”). Subsequently notice under section 148 of the Act was issued to the assessee and the assessee filed his return of income on 2/11/2018 declaring the same income

Harbhajansingh Bawansingh Heer, Mumbai vs. Asstt.Commissioner of Income Tax, Mumbai

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

ITA 4313/MUM/2023[2011-12]Status: DisposedITAT Mumbai08 Aug 2024AY 2011-12

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri R.R.Makwana, Sr.DR
Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(b)Section 69

deposited cash of INR 17,75,292 in his saving bank account, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 27/03/2018. Thereafter, statutory notices under section 142(1) along with questionnaire were issued to the assessee. However, there

ITO, Ward-2(1)(3), Ahmedabad vs. M/S. Lydia Construction Pvt. Ltd., Ahmedabad

ITA 729/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad07 Aug 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: NoneFor Respondent: Shri Kamlesh Makwana, CIT DR
Section 133(6)Section 143(1)Section 148Section 271(1)(c)Section 68

having received Rs. 9 crore in accommodation entries during the impugned assessment year. Based on this information, the assessment was reopened, and a notice under Section 148 was issued. The assessee responded by confirming that their original return should be treated as the return of income in response

Naresh Brothers, Mumbai vs. ITO-17(2)(4), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 948/MUM/2024[2012-13]Status: DisposedITAT Mumbai07 Aug 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm A.Y.2012-13 Naresh Brothers The Income Tax Officer 407, 4Th Floor, Dhiraj Ward 17 (2) (4) Heritage, Near Bus Depot, Mumbai Vs. Sv Road, Santacruz (W), Mumbai 400054

Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 151Section 69C

Ajay Maheshwari of bogus purchases. The reasons were recorded, an approval was obtained under section 151 and notice under section 151 and notice under section 148 of the Act was issued on 30.03.2019. The reasons of reopening were provided to the assessee. Further, notices under section 142(1) were issued

DCIT, Gurugram vs. Rajesh Kumar, Sonepat

In the result, cross-appeal filed by the Revenue is dismissed

ITA 82/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Aug 2024AY 2018-19

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 40Section 41(1)Section 43BSection 68

CHANDIGARH) 4 . Vardhman Holding Ltd. vs. ACIT, Circle 1, Ludhiana We do not find the act of the Assessing Officer in issuing notice under section 148 of the Act, within the time limit available for issue of notice under section 143(2) of the Act being ... chaotic situation. If the Assessing Officer has time in his hands to issue notice under section 143(2), why is he issuing notice under section 148 of the Act, we do not understand, specifically in the background of the legal position that the scope of assessment made on issue

Rajesh Kumar, Sonepat vs. ACIT, Central Circle-2, Gurgaon

In the result, cross-appeal filed by the Revenue is dismissed

ITA 61/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Aug 2024AY 2018-19

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra[Assessment Year : 2018-19] Rajesh Kumar, Vs Acit, C/O-Shiva Constructions Co., Central Circle-2, Plot No.69, Sidharth Enclave, Gurgaon. Delhi Road Sonipat, Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent [Assessment Year : 2018-19] Dcit, Vs Rajesh Kumar, Gurgaon. C/O-Shiva Constructions Co., Plot No.69, Sidharth Enclave, Delhi Road,Sonipat, Haryana-131001. Pan-Bkspk2518K Appellant Respondent Appellant By Shri Umesh Takkar, Ca & Shri Saurabh Nagpal, Ca Respondent By Shri P N Barnwal, Sr.Dr Date Of Hearing 03.07.2024 Date Of Pronouncement 07.08.2024 Order Per Kul Bharat, Jm : These Two Cross-Appeals Filed By The Assessee & The Revenue, Are Directed Against The Order Passed By Ld. Commissioner Of Income Tax(Appeals) [“Ld.Cit(A)”]-3, Gurgaon Dated 31.10.2022 For The Assessment Year 2018-19. Both Appeals Of The Assessee & The Revenue Are Heard Together & Are Being Disposed Off By Way Of Common Order For The Sake Of Brevity.

Section 133ASection 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 40Section 41(1)Section 43BSection 68

CHANDIGARH) 4 . Vardhman Holding Ltd. vs. ACIT, Circle 1, Ludhiana We do not find the act of the Assessing Officer in issuing notice under section 148 of the Act, within the time limit available for issue of notice under section 143(2) of the Act being ... chaotic situation. If the Assessing Officer has time in his hands to issue notice under section 143(2), why is he issuing notice under section 148 of the Act, we do not understand, specifically in the background of the legal position that the scope of assessment made on issue

Late Smt. Mariam Bai (Through Legal Heir Shri Abdul Razak Chara), Indore (M.P.) vs. The Income-Tax Officer - 4(3), Indore, Indore (M.P.)

In the result appeal of the assessee is partly allowed

ITA 249/IND/2024[2015-16]Status: HeardITAT Indore06 Aug 2024AY 2015-16

Bench: Shri Manish Boradsmt. Mariam Bai (Through Income Tax Officer 4(3), Legal Heir Shri Abdul Razak Indore Chara), Vs. 12, Daulaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Advpc5505A Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 05.08.2024 Date Of Pronouncement 06.08.2024 O R D E R

Section 147Section 148Section 69A

Assessing Officer erred in initiating reassessment proceedings under section 147 of the Income-Tax Act, 1961 even when notice under section 148 of the Act was not served to the appellant. 3. That on the facts and in the circumstances of the case and in law, the Ld. Assessing Officer

Income Tax Officer 13(1)(1) Mumbai, Mumbai vs. Nirnay Commodities and Derivatives Pvt Ltd, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2963/MUM/2024[2015]Status: DisposedITAT Mumbai06 Aug 2024

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

For Appellant: NoneFor Respondent: Shri Sridhar G. Menon, Sr. DR
Section 143(2)Section 148Section 68

basis of said information, the AO had the reason to believe that the income chargeable to tax has escaped assessment and accordingly served notice under section 148 of the Income Tax Act, 1961 (the Act) on the assessee and the assessee filed the return of income in response to notice

ITO-42(1)(1), Mumbai, Income Tax vs. Ashwin Moolchand Madhani, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 2273/MUM/2024[2009-10]Status: DisposedITAT Mumbai06 Aug 2024AY 2009-10

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Shri R.U.JainFor Respondent: Shri R. R. Makwana, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

through DGIT (Investigation) that the assessee has taken entries of non-genuine purchases to the tune of INR 60,60,302, and accordingly, notice under section 148 of the Act was issued and served on the assessee. In response to the statutory notices issued under section 143(2) as well

Shah Sandeep Anantkumar HUF, Mumbai vs. ITO-32(3)(4), Mumbai

In the result, the appeal by the assessee is allowed

ITA 4628/MUM/2023[2012-13]Status: DisposedITAT Mumbai06 Aug 2024AY 2012-13

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Shri Rajesh KothariFor Respondent: Shri R.R.Makwana, Sr.DR
Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68Section 69A

consideration of Rs.31,56,000 during the year under consideration, proceedings under section 147 of the Act were initiated, and notice under section 148 of the Act was issued on 31/03/2018. In response to the aforesaid notice, the assessee filed the submission requesting that the return originally filed on 30/07/2012