“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

Sarita Gupta, Saharanpur vs. ITO Ward 3(3)(5) Saharanpur, Saharanpur

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

ITA 3822/DEL/2023[2015-16]Status: DisposedITAT Delhi10 Apr 2024AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2015-16

For Appellant: Shri Vivek Bansal, AdvocateFor Respondent: Shri Anuj Garg, Sr. DR

liability of Rs. 1,01,33,862/- equivalent to her share in the LLP, her case was re-opened by issue of notice under section 148 of the Income Tax, Act, 1961 (the “Act”) on 09.03.2018 with prior approval of Ld. JCIT. During the course of re-assessment proceedings

Surinder Films(P) Ltd., Kolkata vs. DCIT, Cir-3(1), Kolkata.

In the result, appeal of the assessee is allowed

ITA 1360/KOL/2023[2012-13]Status: DisposedITAT Kolkata09 Apr 2024AY 2012-13

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 1360/Kol/2023 Assessment Year: 2012-13 Surinder Films (P) Ltd. Dy. Commissioner Of Income Tax, C/O Subash Agarwal & Associates Vs Circle-3(1), Kolkata Advocates Siddha Gibson 1, Gibson Lane Suite 213, 2Nd Floor Kolkata - 700069 [Pan : Aancs0075K] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Siddharth Agarwal, Advocate Revenue By : Shri Arun Kumar Meena, Jcit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 08/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 09/04/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre, Delhi (Hereinafter The “Ld. Cit(A)”) Dt. 23/11/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal:- 1. (A) For That The Ld. Cit(A) Was Not Justified In Upholding The Validity Of Re-Opening Proceedings U/S 147 Which Was Without Jurisdiction & As Such, Not Sustainable In The Eyes Of Law. (B) For That The Purported Approval Granted By The Principal Cit - 1, Kolkata U/S 151, If Any, Does Not Fulfill The Requirements Of Law Thereby Vitiating The Entire Proceedings. 2. For That The Ld. Cit(A) Was Not Justified In Confirming The Addition Made By The A.O. Of Rs. 30,00,000/- On Account Of Unsecured Loan Received From Mirabelle Tradecom Pvt Ltd. U/S 68. 2

For Appellant: Shri Siddharth Agarwal, AdvocateFor Respondent: Shri Arun Kumar Meena, JCIT, Sr. D/R

Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250Section 68Section 69C

escaped assessment for which the Return of AY 2012-13 needs to be reassessed u/s 147,Necessary sanction to issue notice under section 148 has been obtained separately from Pr. CIT- 1, Kolkata as per the provision of section 151 of the I.T. Act. If you have any objection ... there must still be some reasons which warrant the holding of a belief so as to necessitate the issuance of a notice under section 148 of the Act. Looked at in the light of the decisions placed before us and the law laid down therein, it is necessary to appreciate

ACIT, Cent Circle-1, Trichy vs. M/S Mangal & Mangal, Trichy

In the result, appeal filed by the revenue is dismissed

ITA 511/CHNY/2022[2012-13]Status: DisposedITAT Chennai09 Apr 2024AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 511/Chny/2022 िनधा"रण वष" / Assessment Year: 2012-13 The Assistant Commissioner Of M/S. Mangal & Mangal, Income Tax, V. 25, N.S.B. Road, Teppakulam, Central Circle -2, Trichy – 620 002. No. 44, Williams Road, [Pan: Aaifm-3378-B] Cantonment, Trichy – 620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. S. Sridhar, Advocate : Shri. Nlay Baran Som, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 06.02.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. S. Sridhar, Advocate

Section 143(3)Section 147Section 148

opinion cannot be allowed. In our opinion, therefore, in the present case also, it was not permissible for respondent No. 1 to issue notice under section 148. 20. Further, the Hon'ble Supreme Court held in the case of CIT Vs. Kelvinator of India Ltd, 320 ITR 561 that ... opinion cannot be allowed. In our opinion, therefore, in the present case also, it was not permissible for respondent No. 1 to issue notice under section 148.” 14. The Ld. Counsel for the assessee, had also relied upon the decision of Hon’ble Supreme Court in the case

Sh. Badaluram, Fauladpur, Alwar vs. ITO, Ward-Behror, Behror

In the result, the appeal of the assessee is allowed

ITA 720/JPR/2023[2017-18]Status: DisposedITAT Jaipur09 Apr 2024AY 2017-18

For Appellant: Shri P.C. Parwal, (C.A.)For Respondent: Shri A.S. Nehra (Addl.CIT)

Section 142(1)Section 147Section 148Section 69

declaring total income at Rs.3,94,820/- against the notice u/s 148 which was beyond the due date. In this case, notice under section 148 of the Income-tax Act, 1961 (hereinafter, the Act) was issued 30.03.2021. In terms of the said notice, the assessee was required to file

Late Sh. Birdi Chand Through Legal Heir Mukesh Sharma, Jaipur vs. ITO, Ward-7(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 502/JPR/2023[2012-13]Status: DisposedITAT Jaipur09 Apr 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

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

Section 139(1)Section 142(1)Section 143(3)Section 148Section 292BSection 54F

dead person and hence, such notice is null and void. To initiate proceedings under section 147 of the Act, issuance of notice under section 148 of the Act to the heirs and legal representatives of the deceased is mandatory, in the absence of which the proceedings cannot be continued ... decision of this court in Rasid Lala v. Income Tax Officer, Ward-1(3)(6), [2017] 77 taxmann.com 39 (Guj.), wherein the notice under section 148 of the Act was issued to the assessee long after he had passed away. The heir of the deceased informed the Assessing Officer that

Maddikunta Sanjeeva Reddy, Hyderabad vs. Income Tax Officer, Ward-1, Sangareddy

In the result, the appeal of the assessee is allowed

ITA 230/HYD/2024[2013-14]Status: DisposedITAT Hyderabad08 Apr 2024AY 2013-14

Bench: Shri Laliet Kumarassessment Year: 2013-14 Maddikunta Sanjeeva Vs. The Income Tax Officer, Reddy, Ward – 1, Hno11-222/1, Sangareddy. Shanthinagar Colony, Patancheru, Hyderabad – 502319, Telangana. Pan : Eiyps0245H (Appellant) (Respondent) Assessee By: Shri Kali Kiran Kumar Kovvada, Ca. Revenue By: Shri Ranjan Agarwala, Sr.Ar Date Of Hearing: 08.04.2024 Date Of Pronouncement: 08.04.2024

For Appellant: Shri Kali Kiran Kumar KovvadaFor Respondent: Shri Ranjan Agarwala, Sr.AR

Section 147

Assessing Officer to ensure that no proceedings should be initiated against the deceased person or assessee. 7.1 In the present case, a notice under section 148 of the Act was issued against the deceased / dead person. Despite the fact of death came to the notice of Assessing Officer, no fresh ... notice under section 148 of the Act, as permissible in law was issued against the legal heirs within the period of limitation. In my view, there is a failure on the part of the Assessing Officer to issue notice u/s 148 against all the legal heirs and the notice

Jyoti Rakesh Roongta, Kolkata vs. ITO, Ward-43(5), Kolkata

In the result, the appeal of the assessee is allowed

ITA 143/KOL/2024[2012-13]Status: DisposedITAT Kolkata08 Apr 2024AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 143/Kol/2024 Assessment Year: 2012-2013 Jyoti Rakesh Roongta,…………………………….Appellant Suite-F, 4Th Floor, Mission Court, 25, R.N. Mukherjee Road, Kolkata-700001 [Pan:Adjpr8090H] -Vs.- Income Tax Officer,…………………………….…Respondent Ward-43(5), Kolkata, 3, Government Place, Kolkata-700001 Appearances By: Shri S.K. Pransukhka, Fca, Appeared On Behalf Of The Assessee Shri B.K. Singh, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : April 08, 2024 Date Of Pronouncing The Order : April 08, 2024 O R D E R

Section 10(38)(b)Section 142(1)Section 148Section 50C

return of income on 23.03.2013 declaring income of Rs.11,36,360/-. The ld. Assessing Officer has reopened the assessment by issuance of a notice under section 148. The ld. Assessing Officer was of the view that he got an information from the ld. DDIT (Inv.), Unit-2(1), Kolkata exhibiting

Spectrum Foods Limited, Jaipur vs. Income Tax Officer, Jaipur

In the result, the appeal of the assessee is allowed

ITA 38/JPR/2024[2010-11]Status: DisposedITAT Jaipur08 Apr 2024AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Anup Singh (Addl. CIT)

Section 143(3)Section 147Section 148

which is void ab initio and deserves to be quashed. 4. In this case, as mentioned in the assessment order, notice under section 148 was issued on 29/03/2015 by DCIT, Circle-6, Jaipur. The reasons on which notice was issued have also been reproduced in the assessment order on Page ... this was not vague or general, but rather specific. Furthermore, when he came across information the AO did not issue notice under section 148 of the Act rather, he examined the information, applied his mind to it and formed the prima facie belief that income chargeable to tax had escaped

Ubmc Trust Association, Udupi vs. Income-Tax Officer, Exemptions Ward-1, Mangalore

In the result, both the appeals filed by assessee stands allowed on the legal issue raised in the additional ground

ITA 694/BANG/2023[2015-16]Status: DisposedITAT Bangalore08 Apr 2024AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Ravi Shankar .S.V

Section 12ASection 142(1)Section 234ASection 250

assessment year 2014-15 on 02.12.2016 declaring NIL income. The case of the appellant was reopened for assessment by issuing a notice under section 148 of the Act and an order under section 143(3) r.ws147 of the Act came to be passed on 26.'12.2018 wherein addition of Rs.72 ... such record. d. A RTI application was filed and the learned assessing officer provided the copies of reasons recorded based on which the notice under section 148 was issued. The present counsel advised that additional grounds of appeal Page 7 of 18 ITA Nos. 693 & 694/Bang/2023 were required

Ubmc Trust Association, Udupi vs. Income-Tax Officer, Exemptions Ward-1, Mangalore

In the result, both the appeals filed by assessee stands allowed on the legal issue raised in the additional ground

ITA 693/BANG/2023[2014-15]Status: DisposedITAT Bangalore08 Apr 2024AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Ravi Shankar .S.V

Section 12ASection 142(1)Section 234ASection 250

Shrikant Ramesh Merchant, Mumbai vs. ACIT in Situ ITO -19 (3) (3), Mumbai

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

ITA 296/MUM/2022[2013-14]Status: DisposedITAT Mumbai08 Apr 2024AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Sandeep Singh Karhail (Jm)

Section 10(38)Section 131Section 133(6)Section 148Section 68

long term capital gains declared by the assessee is bogus in nature and accordingly reopened assessment of AY 2013-14 by issuing notice under section 148 of the Act. In the reopened assessment, the Assessing Officer referred extensively to the report given by the investigation wing with regard

Anavya Investments Pvt. Ltd., New Delhi vs. ITO Ward-2(4), New Delhi

In the result, appeal of the assessee is allowed

ITA 4828/DEL/2019[2010-11]Status: DisposedITAT Delhi08 Apr 2024AY 2010-11

Bench: Shri C. N. Prasad & Shri M. Balaganeshm/S. Anavya Investments Pvt. Ltd, Vs. Ito, C/O. Sanjay & Sanjay, A-1-A, 14B, Ward-2(4), Janakpuri, New Delhi New Delhi (Appellant) (Respondent) Pan:Aahc4820A Assessee By : Shri Sanjay Garg, Ca Shri Akarsh Garg, Adv Revenue By: Shri Kanv Bali, Sr. Dr Date Of Hearing 11/01/2024 Date Of Pronouncement 08/04/2024

For Appellant: Shri Sanjay Garg, CAFor Respondent: Shri Kanv Bali, Sr. DR

Section 115JSection 139(1)Section 143(3)Section 147Section 148Section 68

that the reassessment proceedings by the learned AO are bad in the eye of low as the reasons recorded for the issue of notice under Section 148 are bad in the eye of low and are contrary to the facts. 5. On the facts and circumstances of the case

M/S. Global Ship Trade Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(2), Bhavnagar

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

ITA 1039/AHD/2014[2005-06]Status: DisposedITAT Ahmedabad05 Apr 2024AY 2005-06

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2005-06 M/S.Global Ship Trade P.Ltd. Ito, Ward-1(2) 321, Madhav Hill Vs Bhavnagar. Waghawadi Road Bhavnagar. Pan : Aadcg 1889 K (Applicant) (Responent) : Shri B.R. Popat, Ar Assessee By : Shri Sushil Kumar Katiar, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 07/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 05/04/2024 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Sushil Kumar Katiar, Sr.DR

Section 133ASection 143(3)Section 147Section 148Section 250(6)Section 69A

impugned year, and the transactions thereof were not reflected in the return of income. The case of the assessee was reopened by issuing notice under section 148 of the Act on 19.3.2012. Thereafter assessment was framed under section 147 of the Act, treating the amount received by the assessee

Assistant Commissioner of Income Tax, Chennai vs. Thiruthuraipoondi Tiruvenkadam Vivekanandam Dhinakaran, Chennai

In the result, both the appeals filed by the Revenue are dismissed

ITA 1423/CHNY/2023[1996-97]Status: DisposedITAT Chennai05 Apr 2024AY 1996-97

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. Nos.1422 & 1423/Chny/2023 िनधा"रण वष"/Assessment Years: 1995-96 & 1996-97 The Assistant Commissioner Of Vs. Thiruthuraipoondi Tiruvenkadam Income Tax, Central Circle 2(2), Vivekanandam Dhinakaran, Investigation Building, 5, Iv Street, Venkateswara Nagar, Chennai – 34. Karpagam Gardens, Adyar, Chennai 600 020. [Pan:Abkpd2771Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 25.03.2024 घोषणा की तारीख /Date Of Pronouncement : 05.04.2024 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 06.10.2023 Relevant To The Assessment Years 1995-96 & 1996-97. 2. Brief Facts Of The Case Are That The Assessee, Shri Ttv Dhinakaran Has Filed His Return Of Income For The Assessment Years 1995 96 & 2

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT

Section 132ASection 143(3)Section 147Section 148Section 153(3)Section 158B

Court against such show-cause notice. Meanwhile, the Assessing Officer, after recording the reasons under section 147 of the Act, has issued a notice under section 148 of the Act on 15.03.2002 3 I.T.A. Nos. 1422 & 1423/Chny/23 for the assessment years 1995-96 and 1996-97. The assessee filed ... Assessing Officer to invoke the provisions of section 158BC of the Act for the same assessment years, has chosen to issue a notice under section 148 of the Act on 15.03.2002. The Assessing Officer completed the assessment on 31.12.2019 protectively for the AY(S) 1995-96 and 1996-97 under

Assistant Commissioner of Income Tax, Chennai vs. Thiruthuraipoondi Tiruvenkadam Vivekanandam Dhinakaran, Chennai

In the result, both the appeals filed by the Revenue are dismissed

ITA 1422/CHNY/2023[1995-96]Status: DisposedITAT Chennai05 Apr 2024AY 1995-96

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT

Section 132ASection 143(3)Section 147Section 148Section 153(3)Section 158B

DCIT CC 4(4), Mumbai vs. Aspen International Private Limited, Mumbai

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

ITA 3589/MUM/2023[2017-18]Status: DisposedITAT Mumbai05 Apr 2024AY 2017-18

Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 149Section 151Section 69C

2 ITA No.3466/Mum/2023 & others M/s. Aspen International Pvt. Ltd. DCIT, Central Circle- Vs. M/s. Aspen International 4(4) Mumbai Pvt

Goldiam International Limited, Mumbai vs. DCIT- CC 1(2), Mumbai

The appeals of the assessee are allowed partly

ITA 3218/MUM/2023[2016-17]Status: DisposedITAT Mumbai05 Apr 2024AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Goldiam International Limited Plot No.16/17 Gems & Dcit, Central Circle 1(2) Vs. Jewelry Complex Seepz Sez Mumbai Andheri East, Mumbai-400 096 (Appellant) (Respondent) Pan No. Aaacg2271J

For Appellant: Shri Mani Jain, CAFor Respondent: Shri Mirza Azhar, DR

Section 10(35)Section 133ASection 143Section 147Section 148

under section 148A (d) of the act was passed on 28/7/2022 which is approved by the principal Commissioner of income tax. Thereafter the notice under section 148 was issued on 28/7/2022 which was approved by the principal Commissioner of income tax. The learned authorized representative referred to the decision

Blue Coast Infrastructure Development P.Ltd, Solan vs. DCIT, Central Circle-1, New Delhi

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

ITA 2984/DEL/2022[2012-13]Status: DisposedITAT Delhi05 Apr 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Kanv Bali, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 151

that the reassessment proceedings initiated by the AO are bad in the eyes of law, as the reasons recorded for the issue of notice under section 148 are bad in the eyes of law and are contrary to the facts. (ii) On the facts and circumstances of the case, learned

Dhaval Dhushant Vora, Mumbai vs. Assistant Commissioner of Income Tax 33(1), Mumbai

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

ITA 3013/MUM/2023[2011-12]Status: DisposedITAT Mumbai04 Apr 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry, Jm & Ms Padmavathy S, Am

For Appellant: Shri Viraj Mehta, CAFor Respondent: Smt. Mahita Nair, Sr. DR

Section 132Section 132(4)Section 147Section 148Section 151Section 153Section 69

whose place of business was searched under section 132 of the Income Tax Act, 1961 (the Act) the Assessing Officer (AO) issued a notice under section 148 of the Act by reopening the assessment of the assessee. The assessee vide letter dated 02.04.2018 requested the AO to treat the original ... return filed as the return filed in response to notice under section 148 of the Act. The AO issued the show-cause notice on 30.11.2018 asking the assessee why the amount of Rs. 75,00,000/- should not be added as the income of the assessee. The assessee filed

Kunwar Pal Singh, Ghaziabad vs. ITO Ward - 1(3), Ghaziabad

In the result, the impugned notice is quashed

ITA 172/DEL/2020[2010-11]Status: DisposedITAT Delhi04 Apr 2024AY 2010-11

Bench: learned first appellate authority, inter alia, challenging the reopening of the assessment under section 147 of the Act.

Section 139(1)Section 144Section 147

paragraph no.1 and 2 of the Purti Parab 3/4 420-WP-3224-2019.doc petition, Respondent No.1 simply says that these are factual in nature and the notice under Section 148 dated 26th March, 2019 and the order disposing the objections and the notice dated 22nd October, 2019 are issued in pursuance ... even bothered to annex the sanction obtained which gives us a feeling that the said Mr. Ramesh C. Meena who issued notice under Section 148 of the Act containing errors of facts and who has filed affidavit in reply does not wish to produce the same. We have to, therefore