← All Phrases

“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

Premji Bhuralal Gala, Mumbai vs. Deputy Commissioner of Income Tax Circle 24(1), Mumbai

In the result, the appeals of the assessee bearing ITA 440/Mum/2024, ITA

ITA 440/MUM/2024[2013-14]Status: DisposedITAT Mumbai12 Jun 2024AY 2013-14

Bench: Shri Anikesh Banerjeeand Shri Gagan Goyal

For Appellant: Shri Anuj KisnadwalaFor Respondent: Shri H.M. Bhatt (SRDR)
Section 132Section 132(4)Section 143(3)Section 144BSection 147Section 148Section 234ASection 250Section 269SSection 271(1)(c)

assessment order is only to justify respondents' allegations that petitioner had contravened the provisions of Section 259SS of the Act. Since the notice under section 148 of the Act is issued only where there is income that has escaped assessment, notice as impugned in the petition could not have been

Naresh Kumar Bhargava, Jaipur vs. Principal Commissioner of Income Tax -1, Jaipur

In the result, appeal of the assessee is allowed

ITA 221/JPR/2024[2013-14]Status: DisposedITAT Jaipur11 Jun 2024AY 2013-14

Bench: The Date Of Hearing.”

For Appellant: Sh. Rohan SoganiFor Respondent: Sh. Anil Dhaka, CIT
Section 132Section 142(1)Section 143(2)Section 147Section 148Section 263

JURISDICTION UNDER SECTION 263 1. ORIGINAL ASSESSMENT PROCEEDINGS 1.1 Case of the assessee, for the captioned assessment year, was reopened by issuance of notice under Section 148. Thereafter, multiple notices/query letters, were issued to the assessee, during the course of such re-assessment proceedings. 1.2 Subsequently, after considering elaborate submissions ... Revenue. In the present case, the Assessing Officer did not make any addition for the reasons recorded at the time of issue of notice under Section 148 of the Act. This position is not disputed and disturbed by the Commissioner of Income Tax in his order under Section

Asso Gums Pvt. Ltd., Jaipur vs. ITO, Ward-6(4), Jaipur

ITA 457/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Jun 2024AY 2012-13

Bench: This Appellate Tribunal By Way Of Appeal.

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Rajesh Ojha (CIT-DR)
Section 143(1)Section 143(3)Section 147Section 148

Admittedly, assessment proceedings under section 147 of the Act were initiated on the basis of information possessed by the Assessing Officer, and thereupon, notice under section 148 of the Act was issued and served upon the assessee. The assessee then filed return of income declaring total income of Rs.57 ... this regard is that the assessee was under bona fide belief that the ground of unexplained sundry creditors being not there in the notice under section 148 of the Act, the assessee was not required to furnish details and documents about sundry creditors. In this regard, Learned AR has also

Income Tax Officer W 1, Hassan vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1166/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under Section 148 can be issued, as provided in Section 149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction

Income Tax Officer, W-1, Vijayanagar vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1165/BANG/2023[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under Section 148 can be issued, as provided in Section 149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction

Income Tax Officer Ward-1 Hassan, Hassan vs. Ramachandra Setty and Songs, Hassan

In the result, appeal of the assessee in ITA

ITA 1164/BANG/2023[2014-15]Status: DisposedITAT Bangalore10 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under Section 148 can be issued, as provided in Section 149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction

Income Tax Officer, W-1, Hassan vs. Ramachandra Setty & Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1163/BANG/2023[2013-14]Status: DisposedITAT Bangalore10 Jun 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under Section 148 can be issued, as provided in Section 149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction

M/S. S. Ramashandra Setty & Sons, Hassan vs. Income Tax Officer, Ward-1, Hassan

In the result, appeal of the assessee in ITA

ITA 1156/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

have been removed by the non obstante clause with which sub-section (1) of Section 153A opens. The time-limit within which the notice under Section 148 can be issued, as provided in Section 149 has also been made inapplicable by the non obstante clause. Section 151 which requires sanction

Gtl Infrastructure Limited, Mumbai vs. Commissioner of Income Tax (Appeal)-NFAC, Mumbai

In the result, the appeal for AY 2016-17 & 2017-18 are allowed for statistical purposes

ITA 781/MUM/2024[2017-18]Status: DisposedITAT Mumbai10 Jun 2024AY 2017-18

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 115JSection 143(3)Section 147Section 148Section 4(2)Section 5

Subsequently a notice under section 148 of the Act was issued for both the AYs stating that there are reasons to belief that the income chargeable to tax has escaped assessment and the assessments were re-opened accordingly. The AO while completing the reassessment under section 147 made an addition

Gtl Infrastructure Limited, Mumbai vs. Commissioner of Income-Tax (Appeals)-NFAC, Mumbai

In the result, the appeal for AY 2016-17 & 2017-18 are allowed for statistical purposes

ITA 780/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Jun 2024AY 2016-17

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 115JSection 143(3)Section 147Section 148Section 4(2)Section 5

Subsequently a notice under section 148 of the Act was issued for both the AYs stating that there are reasons to belief that the income chargeable to tax has escaped assessment and the assessments were re-opened accordingly. The AO while completing the reassessment under section 147 made an addition

Manish Mohan Jindal, Ludhiana vs. Commissioner of Income Tax (Appeals), National Faceless Appeals Centre, Delhi

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

ITA 599/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh07 Jun 2024AY 2013-14

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

For Appellant: Shri B.K. Sharma, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 147Section 148Section 154

furnish any documentary evidence to substantiate his claim before the ADIT(Inv)-1, Ludhiana during the course of investigation, reasons were recorded and notice under section 148 was issued to the assessee. Subsequently, the assessee filed his return of income on 30/03/2021 declaring total income

Abbasbhai Sajaudinbhai Barad, Ahmedabad vs. The Income Tax Officer, Ward-3(2)(1), Ahmedabad

In the result, appeal of the assessee is partly allowed

ITA 1012/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad07 Jun 2024AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2012-13

Section 143Section 144ASection 147Section 148Section 151Section 68Section 69A

Revenue Department, the Assessing Officer found that the assessee deposited cash as stated herein above but did not file any return of income. Notice under Section 148 of the Income Tax Act, 1961 was issued on 22.03.2019 and the same was duly served upon the assessee by Speed Post

Income Tax Officer, Ward-1, Ratnagiri vs. Late Shri Subhash Shankar Waingankar, Through Legal Heir Shri Rushikesh Subhash Waingankar, Ratnagiri

In the result, Cross Objection appeal of the legal

ITA 1057/PUN/2023[2017-18]Status: DisposedITAT Pune07 Jun 2024AY 2017-18

Bench: Dr. Dipak P. Ripote & Shri Vinay Bhamore

Section 147Section 148Section 159Section 250Section 292BSection 46A(3)

Bombay)[13-07-2023] has held as under : Quote “ 17. The issue which falls for consideration is as to whether the impugned notice under section 148 of the I.T. Act, 1961 is issued in the name of dead person said Shri Vasudeo Jambhulkar is enforceable in law. The fact that ... Asstt. CIT [2019] 103 taxmann.com 188/262 Taxman 61/414 ITR 292/104 CCH 0379 MumHC] has observed as under : "7. The issue of a notice under section 148 of the Act is a foundation for reopening of assessment. The sine qua non for acquiring jurisdiction to reopen an assessment is that such

Jainco Transmission Ltd., Kolkata vs. DCIT, Cir. 11(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 410/KOL/2024[2011-12]Status: DisposedITAT Kolkata07 Jun 2024AY 2011-12

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. No. 410/Kol/2024 Assessment Year: 2011-2012 Jainco Transmission Limited,…………………Appellant 70, Diamond Harbour Road, 3Rd Floor, Ekbalpore, Kolkata-700023 [Pan:Aabcj7859G] -Vs.- Deputy Commissioner Of Income Tax,.....…Respondent Circle-11(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Miraj D. Shah, A.R., Appeared On Behalf Of The Assessee Shri P.P. Barman, Sr. D.R. Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : May 15, 2024 Date Of Pronouncing The Order : June 07, 2024 O R D E R

Section 143(1)Section 148Section 68

taken 15 grounds of appeal. However, its grievances revolve around two issues, namely- (a) whether reopening of the assessment by issuance of a notice under section 148 is valid or not; (b) whether an addition of Rs.94,50,000/- deserves to be made to the total income of the assessee ... determining total income of assessee at Rs.10,56,550/-. The ld. Assessing Officer thereafter reopened the assessment by issuance of a notice under section 148 on 27.03.2018. The reasons recorded for reopening the assessment are being reproduced by the ld. Assessing Officer on pages no. 1 & 2. The ld. Assessing

Income Tax Officer, Raisen vs. Late Sudha Agrawal Th. L/H Manmohan Agrawal, Raisen

Appeal is dismissed and assessee’s cross-

ITA 281/IND/2023[2016-17]Status: DisposedITAT Indore06 Jun 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniincome-Tax Officer, Late Smt. Sudha Agrawal, बनाम/ Raisen (L/H: Manmohan Agrawal) Vs. 19/1, Shreeji Enterprise, Near Sbi, Sagar Road, Yashwant Nagar, M.P. (Pan: Abfpa4355G) (Revenue/Appellant) (Assessee/Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 159Section 54F

taxmann.com 46 (Delhi HC), relevant paras are as under: “THE SINE QUA NON FOR ACQUIRING JURISDICTION TO REOPEN AN ASSESSMENT IS THAT NOTICE UNDER SECTION 148 SHOULD BE ISSUED TO A CORRECT PERSON AND NOT TO A DEAD PERSON. CONSEQUENTLY, THE JURISDICTIONAL REQUIREMENT UNDER SECTION 148 ... service of notice was not fulfilled in the present instance. 26. In the opinion of this Court the issuance of a notice under Section 148 of the Act is the foundation for reopening of an assessment. Consequently, the sine qua non for acquiring jurisdiction to reopen an assessment is that

Sheetal Nilesh Sonawane, Kalwa vs. Assessing Officer, NFAC, Delhi

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

ITA 49/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Jun 2024AY 2015-16

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Subodh Ratnaparkhi - CAFor Respondent: Shri Dinesh A Chourasia – CIT DR
Section 115BSection 143(3)Section 144Section 144BSection 147Section 148Section 148ASection 249Section 249(3)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Income Tax Officer Ward 27(3) Haldia, Haldia vs. Goutam Guria, East Medinipur

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

ITA 1028/KOL/2023[2010-11]Status: DisposedITAT Kolkata05 Jun 2024AY 2010-11

Bench: Dr. Manish Borad & Pradip Kumar Choubey

Section 142(1)Section 143(2)Section 144Section 147Section 148Section 250

before passing of the assessment order for returns furnished on or before 1st October, 2005. In respect of returns filed pursuant to notice under section 148 of the Act after 1st October, 2005, it is mandatory to serve notice under section 143(2) of the Act, within the stipulated time

DCIT Corporate Circle 4(1), Chennai vs. Hemalatha Rajan, Chennai

In the result, all three appeals filed by the Revenue are dismissed

ITA 493/CHNY/2020[2009-10]Status: DisposedITAT Chennai05 Jun 2024AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.11/Chny/2020 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Shri Karuppusamy Pandiarajan, Income Tax, Non Corporate Circle 7, No. 61, Tas Enclave, C3, Golden Kings Room No. 608, 6Th Floor, 121, Court, 10Th Main Road, Santhi Colony, N.H. Road, Chennai 600 034. Anna Nagar West Extn., Chennai 40. [Pan: Aadpp4895M] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.492 & 493/Chny/2020 िनधा"रण वष"/Assessment Year: 2009-10 The Deputy Commissioner Of Vs. Smt. Hemalatha Rajan, 3Rd Floor, Golden Kings Court, Income Tax, Corporate Circle 3(2), Chennai 600 034. No. 61, Tas Enclave, Santhi Colony, 10Th Main Road, Anna Nagar West Extn., Chennai 40. [Pan: Aatph2012G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S.P. Chidambaram, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 28.05.2024 घोषणा की तारीख /Date Of Pronouncement : 05.06.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 11/Chny/2020 Filed By The Revenue Is Directed Against The Order Dated 16.10.2019 Passed By The Ld. Cit(A)-8

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 147Section 271(1)(c)

there is an escapement of income from being charged to tax in terms of the provisions of section 147 of the Act, a notice under section 148 of the Act was issued to the assessee on 31.03.2016 and completed the assessment under section 143(3) r.w.s

DCIT Corporate Circle 4(1), Chennai vs. Hemalatha Rajan, Chennai

In the result, all three appeals filed by the Revenue are dismissed

ITA 492/CHNY/2020[2009-10]Status: DisposedITAT Chennai05 Jun 2024AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.11/Chny/2020 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Shri Karuppusamy Pandiarajan, Income Tax, Non Corporate Circle 7, No. 61, Tas Enclave, C3, Golden Kings Room No. 608, 6Th Floor, 121, Court, 10Th Main Road, Santhi Colony, N.H. Road, Chennai 600 034. Anna Nagar West Extn., Chennai 40. [Pan: Aadpp4895M] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.492 & 493/Chny/2020 िनधा"रण वष"/Assessment Year: 2009-10 The Deputy Commissioner Of Vs. Smt. Hemalatha Rajan, 3Rd Floor, Golden Kings Court, Income Tax, Corporate Circle 3(2), Chennai 600 034. No. 61, Tas Enclave, Santhi Colony, 10Th Main Road, Anna Nagar West Extn., Chennai 40. [Pan: Aatph2012G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S.P. Chidambaram, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 28.05.2024 घोषणा की तारीख /Date Of Pronouncement : 05.06.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 11/Chny/2020 Filed By The Revenue Is Directed Against The Order Dated 16.10.2019 Passed By The Ld. Cit(A)-8

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 147Section 271(1)(c)

there is an escapement of income from being charged to tax in terms of the provisions of section 147 of the Act, a notice under section 148 of the Act was issued to the assessee on 31.03.2016 and completed the assessment under section 143(3) r.w.s

ACIT Non Corporate Circle-7, Chennai vs. Karuppusamy Pandiarajan, Chennai

In the result, all three appeals filed by the Revenue are dismissed

ITA 11/CHNY/2020[2009-10]Status: DisposedITAT Chennai05 Jun 2024AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.11/Chny/2020 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Shri Karuppusamy Pandiarajan, Income Tax, Non Corporate Circle 7, No. 61, Tas Enclave, C3, Golden Kings Room No. 608, 6Th Floor, 121, Court, 10Th Main Road, Santhi Colony, N.H. Road, Chennai 600 034. Anna Nagar West Extn., Chennai 40. [Pan: Aadpp4895M] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.492 & 493/Chny/2020 िनधा"रण वष"/Assessment Year: 2009-10 The Deputy Commissioner Of Vs. Smt. Hemalatha Rajan, 3Rd Floor, Golden Kings Court, Income Tax, Corporate Circle 3(2), Chennai 600 034. No. 61, Tas Enclave, Santhi Colony, 10Th Main Road, Anna Nagar West Extn., Chennai 40. [Pan: Aatph2012G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S.P. Chidambaram, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 28.05.2024 घोषणा की तारीख /Date Of Pronouncement : 05.06.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 11/Chny/2020 Filed By The Revenue Is Directed Against The Order Dated 16.10.2019 Passed By The Ld. Cit(A)-8

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 147Section 271(1)(c)

there is an escapement of income from being charged to tax in terms of the provisions of section 147 of the Act, a notice under section 148 of the Act was issued to the assessee on 31.03.2016 and completed the assessment under section 143(3) r.w.s