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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

Shanmugam Ayyappan Pudukkottai, Pudukkottai vs. ITO, Ward-1, Pudukkottai

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

ITA 54/CHNY/2024[2017-18]Status: DisposedITAT Chennai31 Jul 2024AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.54/Chny/2024 िनधा8रण वष8 /Assessment Year: 2017-18 Shanmugam Ayyappan, The Income Tax Officer , Ts No.5643-5644, South 4Th Street, Vs. Ward-1, Pudukkottai – 622 001. Pudukkottai. Tamil Nadu. [Pan: Aeopa 6661B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri I. Dinesh, Advocate Hiथ" की ओर से /Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/Date Of Hearing : 11.07.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश / O R D E R Per Jagadish, A.M : Aforesaid Appeal Filed By The Assessee For Assessment Year (Ay) 2017-18 Arises Out Of The Order Of Learned Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi [Hereinafter “Cit(A)”] Dated 08.12.2023. 2. The Only Effective Ground Of Appeal In This Case Is Against The Challenging Validity Of Assessment Order & Making Addition Of Cash :- 2 -:

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 139(4)Section 142(1)Section 143(2)Section 144Section 148Section 69A

that Assessing Officers shall drop the proceedings u/s. 143(2) of the Act in such cases and reopen the same by issue of notice under section 148 of the Act.” 7. As the assessment order was passed in violation of CBDT Guidelines, supra, the assessment order passed is quashed

Rapti Premises Private Limited, Mumbai vs. ITO, Ward 11(1)(1), Mumbai

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

ITA 303/MUM/2024[2010-11]Status: DisposedITAT Mumbai31 Jul 2024AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2010-11

For Appellant: Shri Vishnu Agarwal, CAFor Respondent: Smt Mahita Nair, Sr. D.R
Section 142(1)Section 143(1)Section 147Section 148Section 250

tapal” on dated 07.04.2017 claimed that the original return filed on 07.06.2017 may be treated as return filed in response to the notice under section 148 of the Act. On the request of the Assessee, the AO vide letter dated 09.05.2017 provided the reasons for reopening. The Assessee vide letter ... fact that before reopening of the case under section 147 of the 7 M/s. Rapti Premises Private Limited Act and issuing the notice under section 148 of the Act, the AO made no exercise to find out the veracity of the case. It appears from the assessment order that

Ajay Bankda, Mumbai vs. DCIT, 8(2)(2), Mumbai

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

ITA 4444/MUM/2023[2011-12]Status: DisposedITAT Mumbai31 Jul 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2011-12

For Appellant: Shri Sunil Hirawat, CAFor Respondent: Shri Manoj Kumar Sinha, Sr. D.R
Section 143(1)Section 143(2)Section 147Section 148Section 250Section 69

under section 148 of the Act, against which the Assessee vide letter dated 29.05.2018 raised an objection that the service of the notice under section 148 of the Act has been effected, after the due date which is bad in law in view of the decision of the Honorable Gujarat ... notice by holding as under: 2. The primary ground that has been raised is that the Income Tax Officer who issued the notice under section 148 of the Act, had no jurisdiction to issue such notice. According to Petitioner as per instruction No. 1/2011 dated 31st January, 2011 issued

Ushaben Prakashkumar Shah, Ahmedabad vs. The Income Tax Office, Ward-1(3)(1), Ahmedabad

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

ITA 340/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad30 Jul 2024AY 2012-13

Bench: Smt.Annapurna Guptaasstt.Year :2012-13 Ushaben Prakashkumar Shah Ito, Ward-1(3)(1) C/O. M.S. Chhajed & Co., Ca Vs Ahmedabad. “Kamal Shanti” Nr.Sardar Patel Statute Ahmedabad. Pan : Blrps 2392 J (Applicant) (Responent) : Shri Chhajed, Ar Assessee By : Revenue By Shri Hrishikesh Hemant Patki, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 25/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 30/07/2024 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Revenue by Shri
Section 144Section 147Section 148Section 249(4)(b)Section 250Section 68

also. He pointed out that the assessee was lady and her assessment for the Asst.Year 012-13 was reopened by issuing notice under section 148 of the Act after six years on 13.3.2019, but having no prior exposure to the income-tax proceedings and being housewife, she was unaware

M/S. Shri Rang Infrastructure Pvt. Ltd., Gandhinagar vs. DCIT, Gandhinagar Circle, Gandhinagar

In the result, appeal of the assessee is partly allowed

ITA 665/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad30 Jul 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

Section 142(1)Section 143(2)Section 143(3)Section 148Section 151Section 68

income was assessed at Rs.2,83,71,720/-. Thereafter, subsequent to certain discrepancies, the assessment was reopened by way of issuance of notice under Section 148 of the Act after recording reasons for reopening the case and obtaining statutory approvals. Notice under Section 148 of the Act was issued ... which was duly served on 22.11.2016. In response to notice under Section 148, return of income was filed by the assessee on 05.10.2017. Copy of reasons was supplied to the assessee on 18.09.2017. Notice under Section 143(2) of the Act dated 06.10.2017 was issued. The Assessing Officer observed that

Mildred Ponnoth, Mumbai vs. Income Tax Officer (International Tax)-3(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1802/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 Jul 2024AY 2016-17

Bench: MS.KAVITHA RAJAGOPAL (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(1)Section 144Section 144C(5)Section 147Section 148Section 148ASection 234A

assessee being a member of the society has received a sum of Rs.53,50,500 pursuant to the terms of the agreement. Accordingly, notice under section 148 of the Act was issued and served on the assessee on 28.03.2018. In response to the said notice, the assessee filed his return

Kapil Goel, Ghaziabad vs. ITO Ward 2(1)(3), Ghaziabad

The appeal of the assessee is allowed for statistical purposes

ITA 1401/DEL/2024[2016-2017]Status: DisposedITAT Delhi30 Jul 2024AY 2016-2017

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 250Section 40A(3)

basis of AIR information of huge cash deposits during the relevant year. The appellant/assessee filed his ITR, in response to the notice under section 148 of the Act, on 12.07.2021 declaring income of Rs.5,27,430/- (the income disclosed the original ITR was alsoRs.5,27,430/-). The appellant/assessee had made

Nunepally Suresh, Hyderabad vs. Income Tax Officer, Ward-11(3), Hyderabad

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

ITA 664/HYD/2024[2010-11]Status: DisposedITAT Hyderabad29 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar

For Appellant: Shri M.V. Joshi, C.A. appeared for Shri M. ChandramoleswaraFor Respondent: Shri AVES Madhukar, Sr.AR
Section 142(1)Section 144Section 147Section 148

sustaining the assessment order passed by the Assessing Officer under section 144 r.w.s. 147 of the I.T.Act, 1961 without service of the mandatory notice under section 148 on the appellant before the statutory time frame limitations. The Ld. NFAC/CIT(A) ought to have considered the fact that the service ... condition to assume the jurisdiction over the appellant to pass the assessment order. Thus, the assessment order passed without service of the mandatory notice under section 148 on the appellant is bad in law and null and void. 4. On the facts and in the circumstances of the case

Nunepally Suresh, Hyderabad vs. Income Tax Officer, Ward-11(3), Hyderabad

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

ITA 663/HYD/2024[2010-11]Status: DisposedITAT Hyderabad29 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar

For Appellant: Shri M.V. Joshi, C.A. appeared for Shri M. ChandramoleswaraFor Respondent: Shri AVES Madhukar, Sr.AR
Section 142(1)Section 144Section 147Section 148

sustaining the assessment order passed by the Assessing Officer under section 144 r.w.s. 147 of the I.T.Act, 1961 without service of the mandatory notice under section 148 on the appellant before the statutory time frame limitations. The Ld. NFAC/CIT(A) ought to have considered the fact that the service ... condition to assume the jurisdiction over the appellant to pass the assessment order. Thus, the assessment order passed without service of the mandatory notice under section 148 on the appellant is bad in law and null and void. 4. On the facts and in the circumstances of the case

Lokanadha Rao Bathina, Visakhapatnam vs. Income-Tax Officer, Ward-3(2), Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 283/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam29 Jul 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.283/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2016-17) Lokanadha Rao Bathina Vs. Income Tax Officer D.No.54-11-33/3/1, Aditya Nagar Ward-3(2) Isukathota-530013 Infinity Towers, Andhra Pradesh Shankaramattam Road [Pan :Apqpb9831H] Visakhapatnam - 530016 (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri I. Kama Sastry, ARFor Respondent: Dr. Aparna Villuri, Sr.AR
Section 133ASection 143(3)Section 148

issued beyond the time provided for in that section/ ground 2. The assessment order is null and void as the notice under section 148 dated 01.05.2018 is issued without DIN and the same is not regularised by 31.10.2019 as mandated by paragraph 7 of CBDT Circular No.19 of 2019 dated ... Financial Year in which the return is furnished. In the present case, the assessee has filed his return of income in response to notice under section 148 of the Act on 19.05.2018 and therefore the notice under section 143(2) of the Act ought to have been served

M/S Venkateswar Medicare Pvt. Ltd., ITO, Ward-2(1) vs. ITO, Ward-2(1), Kolkata

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

ITA 1417/KOL/2023[2016-17]Status: DisposedITAT Kolkata29 Jul 2024AY 2016-17

Bench: Shri Rajesh Kumar, Am& Shri Sonjoy Sarma, Jm]

Section 119Section 143(2)Section 144BSection 147Section 148Section 148ASection 68

issued by the CBDT in exercise of the power of Section 3(1) of the Ordinance extending the time for issue of notice under Section 148 to March 31, 2021. The said notification came into force from June 30, 2020. On September 29, 2020 the Taxation and Other Laws (Relaxation ... President. TOLA was deemed to have come into force on March 31, 2020. In terms of Section 3(1), the time to issue notice under Section 148 of the Income Tax Act (old unsubstituted), stood extended to March 31, 2021. On March 28, 2021, Finance Act, 2021, it received

M/S Venkateswar Medicare Pvt. Ltd., Kolkata vs. ITO, Ward 2(1), Kolkata

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

ITA 1416/KOL/2023[2014-15]Status: DisposedITAT Kolkata29 Jul 2024AY 2014-15

Bench: Shri Rajesh Kumar, Am& Shri Sonjoy Sarma, Jm]

Section 119Section 143(2)Section 144BSection 147Section 148Section 148ASection 68

issued by the CBDT in exercise of the power of Section 3(1) of the Ordinance extending the time for issue of notice under Section 148 to March 31, 2021. The said notification came into force from June 30, 2020. On September 29, 2020 the Taxation and Other Laws (Relaxation ... President. TOLA was deemed to have come into force on March 31, 2020. In terms of Section 3(1), the time to issue notice under Section 148 of the Income Tax Act (old unsubstituted), stood extended to March 31, 2021. On March 28, 2021, Finance Act, 2021, it received

Metal Closures Pvt Ltd, Bangalore vs. ACIT, Circle 4(1)(2), Bangalore

In the result, the appeal of the Revenue is treated as allowed for statistical purpose

ITA 941/BANG/2024[2014-15]Status: DisposedITAT Bangalore29 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Year: 2014-15

For Appellant: Sri R.E. Balasubramanyam, A.RFor Respondent: Sri Subramanian S., D.R
Section 148Section 28Section 36(2)(i)

Private Limited Company engaged in the manufacture of ROPP caps, crown corks, shoe polish containers, battery jackets, lug caps, flash torches etc. A notice under Section 148 of the Income Tax Act, 1961 (in short “The Act”) was issued on 25/03/2017. The basis of reopening of assessment was that

Deputy Commissioner of Income-Tax, Circle-6(1)(1) Bangalore, Koramangala, Bengaluru vs. Shri Bommai Sommappa Basavaraj, Bangalore

In the result, Appeal of the Revenue is dismissed and CO filed by the assessee is dismissed, as not pressed

ITA 922/BANG/2024[2010-11]Status: DisposedITAT Bangalore29 Jul 2024AY 2010-11

Bench: Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Shri. Sandeep Chalapathy, CAFor Respondent: Shri
Section 147Section 148Section 148(2)Section 250Section 250(4)

appeals before this Tribunal. Accordingly, the appeals are admitted for adjudication. 5. Facts of the case are that the assessee was issued with notice under section 148 of the Act for assessment years 2009-10 and 2010- 11. The assessment was completed after making an addition of ITA Nos.914

Deputy Commissioner of Income-Tax, Circle-6(1)(1) Bangalore, Koramangala, Bengaluru vs. Shri Bommai Sommappa Basavaraj, Bangalore

In the result, Appeal of the Revenue is dismissed and CO filed by the assessee is dismissed, as not pressed

ITA 914/BANG/2024[2009-10]Status: DisposedITAT Bangalore29 Jul 2024AY 2009-10

Bench: Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Shri. Sandeep Chalapathy, CAFor Respondent: Shri
Section 147Section 148Section 148(2)Section 250Section 250(4)

appeals before this Tribunal. Accordingly, the appeals are admitted for adjudication. 5. Facts of the case are that the assessee was issued with notice under section 148 of the Act for assessment years 2009-10 and 2010- 11. The assessment was completed after making an addition of ITA Nos.914

Bharatkumar Anraj Bhansali, Mumbai vs. ITO-19(1)(2), Mumbai

In the result, ground number 1, 2, 4 and 5 of the appeal are dismissed

ITA 340/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Jul 2024AY 2009-10

Bench: Shri Prashant Maharishi (Am) I.T.A. No. 340/Mum/2024 (A.Y. 2009-10) Bharat Kumar Anraj Bhansali Vs. Ito, Ward 19(1)(2) Room No. 10, 3Rd Floor. Matru Mandir Saraswat Building 2Nd Floor Banganga Road Tardeo Road Walkeshwar, Mumbai-400 Mumbai-400 007. 006. Pan : Aaepb8134C (Appellant) (Respondent) Assessee By Shri Ravi Gupta Department By Shri R.R. Makwana Date Of Hearing 10.06.2024 Date Of Pronouncement 29.07.2024 O R D E R 1. This Appeal Is Filed By The Assessee Against The Appellate Order Passed By The National Faceless Appeal Centre (Nfac) Delhi (The Learned Cit – A) For Assessment Year 2009 – 10 Dated 24/2/2023 Wherein The Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 147 With Section 148 Read With Section 144 Of The Income Tax Act, 1961 Dated 28/3/2015 Was Dismissed. 2. Therefore, The Assessee Is Aggrieved With The Same Has Preferred This Appeal Raising Several Grounds. 3. The Fact Of The Case Shows That The Assessee Is An Individual Where He Filed His Return Of Income Declaring Total Income Of Rs. 164,870 As He Is Dealing As A Trader In Farah’S & Nonferrous Metal. The Name Of The Assessee Appears As A Beneficiary In Obtaining Accommodation Entries & Hawala Bills From Non-Existing Entity Is Discovered By Maharashtra Sales Tax Department & Information Passed On To The Assessing Officer By The Director General Of Income Tax, Investigation

Section 142Section 144Section 147Section 148

investigation Wing, Mumbai that assessee has made purchases of Rs. 3,620,179/– from one party namely Sai Kripa metallic traders. Therefore, the notice under section 148 was issued on 19/2/2014 which was not responded to. Further notices under section 142 (1) were issued to the assessee and there ... information available from the sales tax department as well as the director general of income tax investigation. Assessee did not respond to the notice under section 148 of the act. He did not file the return of income as well as did not file any objection before the learned

Mr. Mohamadli Shaikh, Mumbai vs. ITO-21(2)(3), Mumbai

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

ITA 335/MUM/2024[2010-11]Status: DisposedITAT Mumbai29 Jul 2024AY 2010-11

Bench: Shri Prashant Maharishi, Am Mr. Mohamadli Shaikh Ito, Ward 21(2)(3), Room No.4, Second Floor, Aaykar Bhavan, 107, Hari Jairam Bldg, Mauland Vs. Azad Road, Mumbai-400 020 Jalob Circle, Mumbai-400 011 (Appellant) (Respondent) Pan No. Creps9674R

For Appellant: Shri Akhilesh Deshmukh, ARFor Respondent: Shri R.R. Makwana, DR
Section 143Section 143(2)Section 143(3)Section 147Section 148Section 22Section 44ASection 68

assessee has not filed return of income the source of the above fund was not known. Accordingly, reasons were recorded and notice under Section 148 of the Income-tax Act, 1961 (the Act) was issued on 30th March, 2017. The assessee filed his return of income declaring total income ... lower authorities, we find that assessee though did not file any return of income u/s 139 of the Act , but in response to notice under Section 148 of the Mr. Mohamadli Shaikh; A.Y. 2010-11 Act, filed his return of income declaring total income of ₹2,13,130/-. This income

Mohanlal Magana Ram Ghanchi, Kandivali West vs. Income Tax Officer, Valsad

In the result both the appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 2315/MUM/2024[2010-2011]Status: DisposedITAT Mumbai29 Jul 2024AY 2010-2011

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm

For Appellant: Shri Jagadeesh ChaudharyFor Respondent: Shri Rajnish Yadav , SR DR
Section 133Section 144Section 147Section 148

filed his return of income on 5/1/2012 declaring a total income of Rs. 153,270/–. Subsequently, the case was reopened with issuance of notice under section 148 of the income tax act, 1961 on 25/3/2017. The assessment was completed under section 144 read with section 147 of the income

Mohanlal Magana Ram Ghanchi, Kandivali West vs. Income Tax Officer, Valsad, Gujrat

In the result both the appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 2314/MUM/2024[2011-2012]Status: DisposedITAT Mumbai29 Jul 2024AY 2011-2012

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm

For Appellant: Shri Jagadeesh ChaudharyFor Respondent: Shri Rajnish Yadav , SR DR
Section 133Section 144Section 147Section 148

filed his return of income on 5/1/2012 declaring a total income of Rs. 153,270/–. Subsequently, the case was reopened with issuance of notice under section 148 of the income tax act, 1961 on 25/3/2017. The assessment was completed under section 144 read with section 147 of the income

Ajit Metal Syndicate, Mumbai - Gulalwadi vs. Income Tax Officer Ward 19(1)(1), Mumbai, Mumbai Lalbaug

The appeal of the assessee is allowed for statistical purposes

ITA 2307/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Jul 2024AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm M/S Ajit Metal Syndicate Vs. Income Tax Officer, Ward 19 (1) (1) 123, Kika Street Gulalwadi Piramal Chambers Mumbai – 4 Lal Baug Parel Mumbai-400 012 (Appellant) (Respondent) Pan No. Aaafa1651M Assessee By : Shri Satyaprakash Singh Ca Revenue By : Shri Rajnish Yadav , Sr Dr

For Appellant: Shri Satyaprakash Singh CAFor Respondent: Shri Rajnish Yadav , SR DR
Section 142Section 143Section 145Section 147Section 148Section 249

purchase of Rs. 15,616,653/– as inflated nongenuine purchases from 21 parties who have issued false bills without delivery of goods. 5. Notice under section 148 of the income tax act was issued to the assessee on 1/3/2014 in response to which the assessee filed a letter dated 6/3/2014