“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

Mdlr Airlines (P) Ltd., New Delhi vs. DCIT Central Circle-14, New Delhi

In the result, assessee’s appeals are allowed as indicated above

ITA 1421/DEL/2023[2008-09]Status: DisposedITAT Delhi29 Apr 2024AY 2008-09

Bench: Shri Saktijit Dey & Shri Naveen Chandraa.Y. 2007-08 A.Y. 2008-09

Section 132Section 142Section 143(3)Section 144Section 153ASection 153DSection 264

section (1) of section151 of the Act provides that after the expiry of four years from the end of the relevant assessment year, notice under section 148 shall not be issued unless the Chief Commissioner or the Commissioner, as the case may be, is satisfied, on the reasons recorded

Mdlr Airlines (P) Ltd., New Delhi vs. DCIT Central Circle-14, New Delhi

In the result, assessee’s appeals are allowed as indicated above

ITA 1420/DEL/2023[2007-08]Status: DisposedITAT Delhi29 Apr 2024AY 2007-08

Bench: Shri Saktijit Dey & Shri Naveen Chandraa.Y. 2007-08 A.Y. 2008-09

Section 132Section 142Section 143(3)Section 144Section 153ASection 153DSection 264

Ykm Holdings Pvt. Ltd., Gurgaon vs. ACIT, Circle-4(1), New Delhi

In the result, appeal of assessee is allowed

ITA 1020/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Apr 2024AY 2015-16

Bench: Sh. Saktijit Dey & Sh. M. Balaganeshykm Holdings Pvt. Ltd. Vs. Acit Signature Tower – A, Circle – 4(1) 14Th Floor, South City New Delhi Gurgaon, Haryana Pan No. Aaacy 0460 B (Appellant) (Respondent) Assessee By Shri Rajkumar, C.A. Shri J. P. Sharma, C.A. Revenue By Shri Vivek Vardhan, Sr. D.R. Date Of Hearing: 05.02.2024 Date Of Pronouncement: 29.04.2024 Order Per M. Balaganesh: 1. This Appeal In Ita No.1020/Del/2019 For A.Y. 2015-16 Arises Out Of The Order By Commissioner Of Income Tax (Appeals)- 1, Gurgaon In Appeal No. 314/17-18 Dated 20.11.2018 (Hereinafter Referred To As Ld Cit(A) In Short) Against The Order Of Assessment Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As Act) Dated 14.12.2017 By The Assistant Commissioner Of Income Tax (Hereinafter Referred To As Ld. Ao). 2

Section 127Section 143(2)Section 143(3)Section 251(1)(a)

objection to reopening on various grounds. 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 ... about Rs. 64,34,663/- and therefore, the jurisdiction will be that of DC/AC and not ITO. Mr. Jain submitted that since notice under section 148 of the Act has been issued by ITO, and not by DC/AC that is by a person who did not have any jurisdiction over

Balwinder Singh, Sangrur vs. ITO, Ward, Sunam

In the result, the appeal of the assessee is allowed

ITA 252/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh26 Apr 2024AY 2011-12

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Dev Ahuja, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR

Section 139Section 139(1)Section 143(3)Section 144Section 148Section 271F

that there was a cash deposit of Rs. 63,85,000/- in his bank account maintained with State Bank of India (SBI) and notice under section 148 was issued. Thereafter assessment proceedings were completed under section 144 of the Act, wherein the addition of Rs. 34,37,500/- was made

Balwinder Singh Bajwa, Sangrur vs. ITO, Ward, Sunam

In the result, the appeal of the assessee is allowed

ITA 251/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh26 Apr 2024AY 2011-12

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Dev Ahuja, AdvocateFor Respondent: Smt. Amanpreet Kaur, Sr. DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 144Section 148Section 69A

inquiries were conducted under section 133(6) but the assessee was unable to furnish source of cash deposited in his bank account. Thereafter, notice under section 148 was issued dt. 29/03/2018. In response to the notice, the assessee did not file any return of income. Thereafter, notice under section

Jagrutiben Ambalal Patel, Ahmedabad vs. The ITO, Ward- 3(2)(7), Ahmedabad

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

ITA 329/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad26 Apr 2024AY 2011-12

Bench: Ms. Suchitra Kambleassessment Year: 2011-12

Section 139(1)Section 144Section 147Section 148

that the assessee had deposited cash of Rs.10,00,500/- during the Assessment Year 2011-12 which was not disclosed in her income. Notice under Section 148 of the Act was issued but the assessee neither filed return nor filed any reply. The Assessment Order was passed under Section

DCIT, Income Tax Mumbai vs. Peacemoon Traders, Mumbai

In the result the appeal of the learned AO is dismissed

ITA 3763/MUM/2023[2012-13]Status: DisposedITAT Mumbai26 Apr 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm Peacemoon Traders Dcit Bw 3181/3182/B-Tower, Room No.506, 5Th Floor, Bharat Diamond Bourse, Vs. Piramal Chamber, Bkc Bandra (E), Lalbaug, Mumbai-400 012 Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaafp4501D

For Appellant: Shri Nishit Gandhi, ARFor Respondent: Shri HM Bhatt, DR

Section 132(4)Section 143Section 147Section 148

purchases from entities controlled by an accommodation entry provider, Mr. Bharwarlal Jain, proceedings under section 147 of the Act were initiated and the notice under section 148 of the Act was issued on 27th March 2014. Subsequently, the assessee was asked to furnish the details of purchases claimed

Income Tax Officer-34(3)(2), Mumbai vs. Pinaki D Panani, Mumbai

In the result appeal filed by the learned AO is dismissed

ITA 3617/MUM/2023[2009-10]Status: DisposedITAT Mumbai25 Apr 2024AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm Income Tax Officer Pinaki D Panani 34(3)(2) 401, Mangal Villa, Vs Room No.233, 2Nd Floor, Khandekar Marg, Vs. Kautilya Bhavan, Bkc, Ville Parle (East) Mumbai-400 051 Mumbai-400 057 (Appellant) (Respondent) Pan No. Aijpp0802A Assessee By : Shri Rahul Hakani, Ar Revenue By : Shri H.M. Bhatt, Dr Date Of Hearing: 23.04.2024 25.04.2024 Date Of Pronouncement :

For Appellant: Shri Rahul Hakani, ARFor Respondent: Shri H.M. Bhatt, DR

Section 143Section 147Section 148Section 69C

income of Rs. 21,813,413/–. Pinaki D Panani; A.Y. 09-10 04. Subsequently the assessment was once again reopened by issue of notice under section 148 on 27/1/2016. The assessee responded by letter dated 8/2/2016 requesting to consider the return filed in assessee’s case for assessment year ... earlier, as return in response to notice under section 148 of the act. The assessee was also provided copy of the reasons recorded for reopening of the cases on 30/5/2016. A notice under section 143 (2) was issued on 30/5/2016. In this case information was received from the director general

ITO-9(2)(1), Mumbai vs. Carnation Agro Estate Pvt Ltd, Mumbai

In the result, all the grounds raised by the learned assessing officer are dismissed

ITA 3577/MUM/2023[2011]Status: DisposedITAT Mumbai25 Apr 2024

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm Carnation Agro Estate Pvt. Ltd. Income Tax Officer Shop No.21, Anuradha Society, Ward 9(2)(1) Near Fire Brigade Station, Room No.601A, Aaykar Bhavan Irla Bridge, S.V. Road, Vs. M.K. Marg, Andheri (W), Mumbai-400 020 Mumbai-400 058 (Appellant) (Respondent) Pan No. Aadcc8897M Assessee By : Shri Amit Agarwal, Ar Revenue By : Ms. Madhu Malati Ghosh, Cit Dr Date Of Hearing: 23.04.2024 Date Of Pronouncement : 25.04.2024

For Appellant: Shri Amit Agarwal, ARFor Respondent: Ms. Madhu Malati Ghosh, CIT DR

Section 143Section 143(3)Section 147Section 148Section 263Section 263(1)

which was processed under section 143 (1) on 15th January, 2012. The case of the assessee was reopened by issue of notice under section 148 of the Act on 28th March, 2018 and assessment under section 143 (3) read with section 147 of the Act was completed on 13th December

Dhaval Exim Private Limited, Mumbai vs. ACIT, 5(1)(2), Mumbai

In the result, the appeal of the assessee stands allowed

ITA 2532/MUM/2023[2012-13]Status: DisposedITAT Mumbai25 Apr 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2012-13 Dhaval Exim Pvt. Ltd., Acit, 5(1)(2), 117-A, 117-A, Panchratna Bldg., Aayakar Bhavan, Vs. Mama Parmanand Marg, Opera Maharishi Karve Road, House, Mumbai-400020. Mumbai-400 004. Pan No. Aadcd 0472 B Appellant Respondent : Mr. Rajesh Shah Assessee By Revenue By : Smt. Mahita Nair, Sr. Dr : 04/04/2024 Date Of Hearing Date Of Pronouncement : 25/04/2024

For Respondent: Mr. Rajesh Shah

Section 143(2)Section 147Section 148Section 151(2)

participates in the However, merely because the Assessee participates in the However, merely because the Assessee participates in the proceedings pursuant to such notice under Section 148 of the proceedings pursuant to such notice under Section 148 of the proceedings pursuant to such notice under Section 148

M/S. Shivam Developers, Gandhinagar vs. The DCIT, Mehsana Circle, Mehsana

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

ITA 226/AHD/2020[2012-13]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2012-13 M/S.Shivam Developers The Dy.Cit Plot No.C/1, 1301, Phase-I Vs Mehsana Circle Gidc, Chhatral, Tal.Kalol Mehsana Dist. Gandhinagar – 382 229 Pan: Abwfs 4815 N अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Hardik Vora, Ar & Shri Daivat Bhatt, Ar Revenue By : Shri Ashesh R. Rewar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 17/04/2024 घोषणा क" तार"ख /Date Of Pronouncement: 24/04/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthe Present Appeal Has Been Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Gandhinagar, Ahmedabad [Hereinafter Referred To As “Cit(A)” In Short] Arising In The Matter Of Assessment Order Passed Under S. 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Relevant To The Assessment Year (Ay) 2012-13. 2. The Assessee Has Raised Following Grounds Of Appeal: M/S.Shivam Developers Vs. Dcit Mehsana Asst. Year : 2012-13

For Appellant: Shri Hardik Vora, AR &For Respondent: Shri Ashesh R. Rewar, Sr.DR

Section 148Section 69C

Others - (2003) 259 ITR 19 (SC) has categorically laid down the procedure to be adopted during reassessment proceedings and clarified that – “… when a notice under Section 148 of the Income tax Act is issued, the proper course of action for the noticee is to file return

Sanjaybhai Ranchhodbhai Patel, Ahmedabad vs. The ACIT, Central Circle-2(4), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 1225/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleassessment Year: 2011-12

Section 133ASection 142Section 143(1)Section 143(2)Section 148Section 14ASection 153ASection 36Section 36(1)(iii)Section 69

year 2011-12 only and the mistake in the paragraph no.2 of the notice is a typographical error as the subject itself mentions notice under Section 148 for the A.Y. 2011-12. As regards reopening not permissible under protective addition, it will not be appropriate as the assessee ... have heard both the parties and perused all the relevant material available on record. It is pertinent to note that the subject of notice under Section 148 of the Act clearly mentions that the Assessment Year is 2011-12 and, therefore, mention of Assessment Year 2009-10 is just

Ravi Gopal Trivedy, Mumbai vs. National E-Assessment Centre, Delhi

ITA 4062/MUM/2023[2013-14]Status: DisposedITAT Mumbai24 Apr 2024AY 2013-14

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am Ravi Gopal Trivedy 402, Sheetal, A Wing, Lokhandwala Complex, Andheri (West), Mumbai-400053 Pan : Abсрт1927А Ι.Τ.Α. No. 4062/Mum/2023 (Assessment Year: 2013-14) Vs. National E-Assessment Centre, Delhi Appellant) Respondent) Appellant/Assessee By Dr. K. Shivaram A/W Mr. Shashi Bekal, Ca Revenue/Respondent By Shri R.R. Makwana, Jcit Date Of Hearing 23.04.2024 Date Of Pronouncement 24.04.2024 Order Per Padmavathy S, Am: This Appeal Is Against The Order Of The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [For Short 'The Cit(A)] Dated 16.10.2023 For The Ay 2013-14. The Assessee Raised The Following Revised Grounds: 2

Section 143(1)Section 148

Assessment Centre. 1.1. That on the facts and circumstances of the case and in law the Ld. NFAC has erred in confirming the notice under section 148 of the Act based on incorrect information and without application of mind and without providing copies of the information received. 1.2. That ... Rs.8,92,238/- thereby booking a fictitious loss of Rs.9,09,787/-. The assessee filed the return of income in response to notice under section 148 of the Act declaring the same income as in the original return. The assessee filed its objections in response to the reason recorded

Dy Commissioner of Income Tax (Exemption)-2(1), Mumbai vs. Sir Dorabji Tata Trust, Mumbai

In the result, appeal filed by the revenue is dismissed and cross appeal filed by the assessee is allowed

ITA 2116/MUM/2023[2013-2014]Status: DisposedITAT Mumbai24 Apr 2024AY 2013-2014

Bench: Shri Narendra Kumar Billaiya, Hon'Bleand**

Section 12ASection 143(3)Section 147Section 148

section 143(3) of the Act vide order dated 31.03.2016. - **6.** Assuming jurisdiction conferred upon him, the ACIT(Exemption), Circle -2, Mumbai issued notice under section 148 of the Act dated 16.03.2020 stating that he has reasons to believe that income chargeable to tax for the year under consideration ... assessment read as under: - "Dear Taxpayer, Thank you for filing your return of income for Assessment Year **2013-14** in response to notice under section 148 of the Act, vide Ack. no. **332250790080420 on 08/04/2020.** 2. While acknowledging the care and diligence you have taken in preparing the return, there

Sir Dorabji Tata Trust, Mumbai vs. CIT (Appeals) NFAC, Mumbai

In the result, appeal filed by the revenue is dismissed and cross appeal filed by the assessee is allowed

ITA 2085/MUM/2023[2013-14]Status: DisposedITAT Mumbai24 Apr 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya, Hon'Bleand**

Section 12ASection 143(3)Section 147Section 148

ITO, Ward-30(4), New Delhi vs. Rashmi Rajiv Mehta, Gurgaon

In the result appeal of the Revenue is dismissed and cross objection is dismissed as not pressed

ITA 4399/DEL/2018[2011-12]Status: DisposedITAT Delhi24 Apr 2024AY 2011-12

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarasstt. Year: 2011-12 Ito, Ward-30(4), Vs. Rashmi Rajiv Mehta New Delhi E-52, Raheja Atlantis, Sector – 31, Nh-8, Gurgaon Haryana Pin 122002 Pan Akspm6239M (Appellant) (Respondent) Co No. 181/Del/2018 Arising Out Of Ita 4399/Del/2018 Asstt. Year 2011-12 Rashmi Rajiv Mehta Vs. Ito, Ward-30(4), E-52, Raheja New Delhi Atlantis, Sector – 31, Nh-8, Gurgaon Haryana Pin 122002 Pan Akspm6239M (Appellant) (Respondent)

For Appellant: Shri Ved Jain, AdvocatFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147Section 148Section 68

filed her income tax return for assessment year 2011-12 and deposited huge cash in her bank account. On 07.11.2014 in response notice under section 148 dated 26.09.2014 declaring an income of Rs. 5,15,540/-. In the assessment order under section 143(3) r.w.s 147 of the Act Learned ... Learned AO computed the figure Rs. 2,54,30,000/- comprising total of AIR information, CIB information and TEP information. In response to notice under section 148 assessee filed her return declaring total income of Rs. 5,15,540/- comprising of short term capital gain

Manisha Prashar, Kharar vs. ITO, Ward-6(4), Mohali

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

ITA 462/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh23 Apr 2024AY 2012-13

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

For Appellant: Shri Amitoz Singh Kamboj, CAFor Respondent: Shri Dharam Vir, JCIT, Sr. DR

Section 143(2)Section 143(3)Section 148Section 69

above grounds during the hearing of the appeal. 3. Briefly the facts of the case are that in this case, notice under section 148 was issued to the assessee on 30/03/2019. As per the information available with the Income Tax Department, the assessee had purchased an immovable property in Sector ... escapement of income and notice u/s 148 was issued after seeking prior approval from the Pr. CIT-2, Chandigarh. 4. In response to notice under section 148, the assessee submitted that she had already filed her return of income on 28/07/2012 and a copy thereof was filed before

Sh. Moti Singh Jodha, Khatipura Road, Jaipur vs. ITO, Ward-1(1), Jaipur

ITA 258/JPR/2024[2015-16]Status: DisposedITAT Jaipur23 Apr 2024AY 2015-16

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Anoop Singh (Addl. CIT)

Section 142(1)Section 144Section 147Section 148Section 271(1)(c)

information about purchase of the immovable property by the assessee for Rs.1,72,50,000/-. Thereupon, case was opened, after necessary approvals. Upon notice under section 148 of the Act, the assessee filed return of income declaring total income of Rs.68,950/-. As observed in the assessment order

Palak Enterprise, Mumbai vs. PCIT, Mumbai-25

In the result appeal is allowed for statistical purposes

ITA 4110/MUM/2023[2011-12]Status: DisposedITAT Mumbai23 Apr 2024AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm Palak Enterprise A/7, Kk Smruti, The Income Tax Officer 27(2) Sant Narshi Mehta Marg, (5) Vashi Income Tax Officer, Near Maneklal Estate, Tower No.6, Vs. Ghatkopar (West), Navi Mumbai-400 703 Mumbai-400 086 (Appellant) (Respondent) Pan No. Aajfp5196P Assessee By : Shri R.K. Jadeja, Ar : Shri H.M. Bhatt, Dr Revenue By Date Of Hearing: 17.04.2024 Date Of Pronouncement : 23.04.2024

For Appellant: Shri R.K. Jadeja, AR

Section 133Section 142Section 144Section 147Section 148Section 151Section 194CSection 246ASection 249Section 250

reasons for reopening are a contractual receipt U/s 194C of Rs. 7,056,638 not recorded in the books of accounts. The notice under section 148 was issued on 21/3/2018. The assessee did not comply with the notice under section 148 of the income tax act by filing any return

Kumudini Narendra Mishra, Nagpur vs. Assistant Commissioner of Income Tax, Circle-4, Nagpur

Appeal is partly allowed for statistical purposes in above terms

ITA 72/NAG/2023[2012-13]Status: DisposedITAT Nagpur22 Apr 2024AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Abhay Agrawal, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 143(3)Section 148

following substantive grounds in the instant appeal : 1. “Whether in the facts and circumstances of the case, the learned AO erred in issuing notice under section 148 of the Act. 2 ITA.No.72/NAG./2023 2. Whether in the facts and circumstances of the case, the learned AO erred in making