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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

Dy. Commissioner of Income Tax Central Circle -1(4), Kolkata vs. K Kalpana Industries India Ltd, Kolkata

In the result, both the appeals of the revenue for Assessment Year

ITA 816/KOL/2023[2012-13]Status: DisposedITAT Kolkata21 Mar 2024AY 2012-13

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. Nos. 815 & 816/Kol/2023 Assessment Year: 2011-12 & 2012-13 Deputy Commissioner Of Income K Kalpana Industries India Ltd., Tax, Central Circle-1(4), Kolkata Vs Kolkata 28, Pretoria Street Kolkata - 700071 [Pan : Aabck2239D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ravi Tulsiyan, Fca Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 06/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/03/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Kolkata [Hereinafter The “Ld. Cit(A)”] Evenly Dt. 25/09/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Years 2011-12 & 2012-13. 2. The Registry Has Pointed Out That There Is A Delay Of 34 Days & 11 Days In Filing Of These Appeals By The Department For Assessment Year 2011-12 & 2012-13 Respectively. After Hearing The Ld. D/R We Are Convinced That It Was Prevented By Sufficient Cause From Filing These Appeals On Time. Though The Department Has Not Filed Any Petition/Application For Condonation, The Hon’Ble Apex Court In The Case Of Sesh Nath Singh & Ors. V. Baidyabati · Sheoraphuli Cooperative Bank

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(3)Section 148Section 250Section 28Section 5

Kelvinator of India Ltd and held as follows: "initiation of the re-assessment proceedings under Section 147 by issuing a notice under Section 148 merely because of the fact that now the Assessing Officer is of the view that the deduction under Section 10A was allowed in excess, was based

Dy. Commissioner of Income Tax Central Circle-1(4), Kolkata vs. K Kalpana Industries India Ltd, Kolkata

In the result, both the appeals of the revenue for Assessment Year

ITA 815/KOL/2023[2011-12]Status: DisposedITAT Kolkata21 Mar 2024AY 2011-12

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. Nos. 815 & 816/Kol/2023 Assessment Year: 2011-12 & 2012-13 Deputy Commissioner Of Income K Kalpana Industries India Ltd., Tax, Central Circle-1(4), Kolkata Vs Kolkata 28, Pretoria Street Kolkata - 700071 [Pan : Aabck2239D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ravi Tulsiyan, Fca Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 06/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/03/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Kolkata [Hereinafter The “Ld. Cit(A)”] Evenly Dt. 25/09/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Years 2011-12 & 2012-13. 2. The Registry Has Pointed Out That There Is A Delay Of 34 Days & 11 Days In Filing Of These Appeals By The Department For Assessment Year 2011-12 & 2012-13 Respectively. After Hearing The Ld. D/R We Are Convinced That It Was Prevented By Sufficient Cause From Filing These Appeals On Time. Though The Department Has Not Filed Any Petition/Application For Condonation, The Hon’Ble Apex Court In The Case Of Sesh Nath Singh & Ors. V. Baidyabati · Sheoraphuli Cooperative Bank

For Appellant: Shri Ravi Tulsiyan, FCAFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 143(3)Section 148Section 250Section 28Section 5

Kelvinator of India Ltd and held as follows: "initiation of the re-assessment proceedings under Section 147 by issuing a notice under Section 148 merely because of the fact that now the Assessing Officer is of the view that the deduction under Section 10A was allowed in excess, was based

Prakruti Infrastructure Pvt Ltd, Mumbai vs. ACIT (CC) 1(3), Mumbai

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

ITA 3527/MUM/2023[2009-10]Status: DisposedITAT Mumbai21 Mar 2024AY 2009-10

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sayeed Nadeem LasaniFor Respondent: Shri H.M. Bhatt
Section 133(6)Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151Section 250Section 68

erred in confirming the action of the Ld. A.O. in reopening the assessment of the Appellant by issuance of the notice under section 148 of the Act without recording valid and proper reasons to show that any income chargeable to tax has escaped assessment. Hence, the notice under section 148 ... erred in confirming the action of the Ld. A.O. in reopening the assessment of the Appellant by issuance of the notice under section 148 of the Act without having proper sanction u/s 151. Hence, the notice under section 148 and subsequent assessment order passed under section 144 r.w.s

Rajat Commercial Enterprises Pvt Ltd, Mumbai vs. DCIT Cir 11(1)(1), Mumbai

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

ITA 30/MUM/2023[2012-13]Status: DisposedITAT Mumbai21 Mar 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

Section 10(38)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68Section 7

companies engaged into by the assessee is ₹6.59 crores. The learned Assessing Officer examined the transaction and found that there is tangible information. Notice under Section 148 of the Income-tax Act, 1961 (the Act) was issued on 26th September, 2016. Assessee reiterated original return of income. The copies ... income filed on 10th April, 2017 and in absence of such notice the assessment is invalid. The learned CIT (A) held that the notice under Section 148 of the Act was issued on 26th September, 2016, which was responded by the assessee by filing letter dated 10th April, 2017, reiterating

Reena Rakesh Kothari, Mumbai vs. Income Tax Officer, WD-26(2)(5), Mumbai

In the result, appeal of assessee is allowed

ITA 2184/MUM/2023[2015-16]Status: DisposedITAT Mumbai21 Mar 2024AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Reena Rakesh Kothari Income Tax Officer 28-A, Kamgar Nagar, Ward 26(2)(5), S.G. Barve Marg, Kautilya Bhavan, Vs. Kurla (East), Bandra, Mumbai-400 051 Mumbai-400 024 (Appellant) (Respondent) Pan No. Ahlpk7422J Assessee By : Shri Prakash Jhunjhunwala, Ca Revenue By : Smt. Mahita Nair, Dr Date Of Hearing: 19.02.2024 Date Of Pronouncement : 21.03.2024

For Appellant: Shri Prakash Jhunjhunwala, CAFor Respondent: Smt. Mahita Nair, DR
Section 10Section 139Section 142Section 143Section 147Section 148Section 151Section 68

Kothari, A.Y. 15-16 “1. On facts and circumstances of the case and in law, learned CIT – A in confirming the validity of notice under section 148 dated 12/9/2016 though has been issued before expiry of the date for filing the return of income under section 139 (4) viz 31/3/2017 ... thereby the notice under section 148 and consequential reassessment order passed under section 147 is bad in law. 2. On the facts and circumstances of the case and in law CIT – A order in confirming the validity of notice under section 148 issued in absence of tangible material

Quality Apparel Exporters Pvt Ltd., Mumbai vs. Asst CIT Circle- 11(1)(1), Mumbai

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

ITA 487/MUM/2020[2000-01]Status: DisposedITAT Mumbai21 Mar 2024AY 2000-01

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Pranit TannaFor Respondent: Shri P.D. Chougule
Section 133ASection 144Section 148Section 250

upholding the action of the Assistant Commissioner of Income- tax-11(1)(1), Mumbai (hereinafter referred to as the Assessing Officer) in issuing notice under section 148 of the Act. The appellants contend that on the facts and in the circumstances of the case and in law, the jurisdictional conditions ... alter or amend the aforestated grounds of appeal.” 4. The issue arising in ground no.1 pertains to the issuance of notice under section 148 of the Act. From the perusal of the record, we find that no notice under section 148 of the Act was ever issued to the assessee

Quality Apparel Exporters Pvt Ltd., Mumbai vs. Asst CIT Circle- 11(1)(1), Mumbai

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

ITA 486/MUM/2020[1999-00]Status: DisposedITAT Mumbai21 Mar 2024AY 1999-00

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Pranit TannaFor Respondent: Shri P.D. Chougule
Section 133ASection 144Section 148Section 250

upholding the action of the Assistant Commissioner of Income- tax-11(1)(1), Mumbai (hereinafter referred to as the Assessing Officer) in issuing notice under section 148 of the Act. The appellants contend that on the facts and in the circumstances of the case and in law, the jurisdictional conditions ... alter or amend the aforestated grounds of appeal.” 4. The issue arising in ground no.1 pertains to the issuance of notice under section 148 of the Act. From the perusal of the record, we find that no notice under section 148 of the Act was ever issued to the assessee

M/S. Peacemoon Traders, Mumbai City vs. ACIT, Cir-19(2), Mumbai

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

ITA 3625/MUM/2023[2012-13]Status: DisposedITAT Mumbai20 Mar 2024AY 2012-13

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit GandhiFor Respondent: Shri H.M. Bhatt
Section 143(3)Section 147Section 148Section 250

accommodation entries of bogus purchases from entities controlled by Mr. Bhanwarlal Jain, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 27/03/2014. In response to the aforesaid notice, the assessee filed a letter requesting to treat the return originally

M/S. Peacemoon Traders Firm, Mumbai vs. ACIT Cir-19(2), Mumbai

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

ITA 3624/MUM/2023[2009-10]Status: DisposedITAT Mumbai20 Mar 2024AY 2009-10

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit GandhiFor Respondent: Shri H.M. Bhatt
Section 143(3)Section 147Section 148Section 250

accommodation entries of bogus purchases from entities controlled by Mr. Bhanwarlal Jain, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 27/03/2014. In response to the aforesaid notice, the assessee filed a letter requesting to treat the return originally

M/S. Peacemoon Traders Firm, Mumbai vs. ACIT Circle 19 (2), Mumbai

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

ITA 3623/MUM/2023[2007-08]Status: DisposedITAT Mumbai20 Mar 2024AY 2007-08

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit GandhiFor Respondent: Shri H.M. Bhatt
Section 143(3)Section 147Section 148Section 250

accommodation entries of bogus purchases from entities controlled by Mr. Bhanwarlal Jain, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 27/03/2014. In response to the aforesaid notice, the assessee filed a letter requesting to treat the return originally

Abhishek Tejraj Doshi, Mumbai vs. Income Tax Officer, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2944/MUM/2023[2013-14]Status: DisposedITAT Mumbai20 Mar 2024AY 2013-14

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleabhishek Tejraj Doshi V. Income Tax Officer 259, 2Nd Floor, Johari Mansion Jurisdiction Circle 19(1), Kalbadevi Road, Kalbadevi Mumbai, Mumbai Mumbai 400002 Pan: Aegpd9279J (Appellant) (Respondent) Shri Anil Sathe Assessee Represented By : Department Represented By : Shri Manoj Kumar Sinha

Section 10(38)Section 131Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 68

availed such entry. 3. The case of the assessee was reopened for assessment under section147 of the Act after obtaining necessary approval. Notice under section 148 of the Act was issued on 15.09.2016 and served on the assessee and a copy of reasons recorded for reopening was provided to Page

Star Tradecom Private Limited., Kolkata vs. I.T.O., Ward - 9(1), Kolkata

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

ITA 52/KOL/2023[2009-2010]Status: FixedITAT Kolkata18 Mar 2024AY 2009-2010

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2009-10

For Appellant: Shri Vikas Surana, FCAFor Respondent: Shri Rajeev Kumar, CIT, DR
Section 143(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 263

assessee. The additional grounds so raised are reproduced as under: “3. For that the reopening proceedings carried out vide issuance of notice under section 148 of the I.T Act on 16.12.2010 and thereafter proceedings completed on 17.03.2011, are bad-in-law and non-est based on decision in ACIT

Gujarat Industries Power Co.Ltd., Baroda vs. The ACIT., Circle-1(1), Baroda

In the result, the appeal filed by the assessee is hereby dismissed

ITA 3049/AHD/2010[1998-99]Status: DisposedITAT Ahmedabad15 Mar 2024AY 1998-99

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 3049 & 3050/Ahd/2010 धििाधरणवरध/Asstt. Years: (1998-1999 & 1999 & 2000) Gujarat Industries Power Company The Asst. Commissioner Of Ltd., Vs. Income Tax, P.O Petrochemicals, Circle-1(1), Baroda-391346. Baroda.

For Appellant: Shri Yogesh Shah, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 147Section 148

Assessing Officer while protectively assessing the petitioner-assessee for the year 1993-94, noted that this was a case for issuance of a notice under section 148, which came to be issued thereafter. When the amount of taxable income and of the tax payable thereon were not ascertained

Murtuza Abdul Gaffar Khan, Mumbai vs. National Faceless Appeal Centre (NFAC), Delhi

In the result, appeal filed by the assessee is allowed

ITA 2698/MUM/2023[2011-12]Status: DisposedITAT Mumbai15 Mar 2024AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Murtuza Abdul Gaffar Khan National Faceless Appeal 339, Voctoria Overbridge Road, Centre (Nfac) Reay Road Darukhana Vs. Delhi, Mumbai-400 010 (Appellant) (Respondent) Pan No. Aghpk2006R Assessee By : Shri Vimal Punmiya, Ca Revenue By : Smt. Mahita Nair, Dr Date Of Hearing: 10.01.2024 Date Of Pronouncement : 15.03.2024

For Appellant: Shri Vimal Punmiya, CAFor Respondent: Smt. Mahita Nair, DR
Section 133(6)Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 68

return of income on 28th September, 2011, at ₹6,72,951/-. The return was processed under Section 143(1) of the Act. The notice under Section 148 of the Act was issued on 30th 04. March, 2018, after recording the reasons. The assessee responded by reiterating the original return filed ... return in response to notice under Section 148 of the Act. He further asked for the reasons recorded which were provided and thereafter, notice under Section 142(1) of the Act was issued. 05. In assessment proceedings and reasons recorded for reopening, It was found that assessee has purchased Murtuza

M/S Star Brillian, Mumbai vs. Asstt. CIT -19(3), Mumbai

In the result, the appeal of the assessee for A

ITA 1552/MUM/2020[2013-14]Status: DisposedITAT Mumbai15 Mar 2024AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri P.D. Chougule, Addl. CIT
Section 142(1)Section 143(2)Section 143(3)Section 147Section 147(3)Section 148

taken accommodation entries of purchases from seven different parties amounting to ₹9,86,03,864/-. Therefore, the case was reopened by issue of notice under Section 148 of the Act on 21st March, 2016, after recording the reasons and obtaining the prior approval. In response to that notice, assessee reiterated

M/S Star Brillian, Mumbai vs. ITO - 19(3)(4), Mumbai

In the result, the appeal of the assessee for A

ITA 1551/MUM/2020[2009-10]Status: DisposedITAT Mumbai15 Mar 2024AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri P.D. Chougule, Addl. CIT
Section 142(1)Section 143(2)Section 143(3)Section 147Section 147(3)Section 148

taken accommodation entries of purchases from seven different parties amounting to ₹9,86,03,864/-. Therefore, the case was reopened by issue of notice under Section 148 of the Act on 21st March, 2016, after recording the reasons and obtaining the prior approval. In response to that notice, assessee reiterated

Decent Financial Services Pvt. Ltd., New Delhi vs. DCIT, Circle- 7(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1393/DEL/2020[2010-11]Status: DisposedITAT Delhi15 Mar 2024AY 2010-11

Bench: Sh. Kulbharat & Dr.B. R.R. Kumarassessment Year: 2010-11 Decent Financial Services Dcit Pvt. Ltd. A-86, Dda Shed, Vs Circle – 7 (1) Okhla Industrial Area, New Delhi Phase-I, New Delhi Pan No.Aaacd2899P (Appellant) (Respondent)

For Appellant: (1) On the fact and circumstances of the ease and in law, the
Section 139Section 143(2)Section 143(3)Section 147Section 148Section 250(6)

learned Commissioner of Income Tax (Appeal)-13, New Delhi erred in holding that the learned assessing officer correctly had issued the notice under section 148 of the act which was not pending for adjudication under rectification proceedings ton 154 of the act. As, no subject matter has been simultaneously been

Karam Singh, Ambala vs. ITO, W-2, Ambala

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

ITA 598/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh14 Mar 2024AY 2017-18

Bench: Shri A.D. Jain & Shri Vikram Singh Yadavआयकर अपील सं./ Ita No. 598/Chd/2023 "नधा"रण वष" / Assessment Year : 2017-18 Karam Singh, Vs. The Ito, S/O Shri Jasmel Singh, बनाम Ward-2, Vill. Akalgarh, Ambala P.O. Kambassi, Tehsil Barara, Dsitrict Ambala 133205 "थायी लेखा सं./Pan No. Atmpb0603R अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: NoneFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 148

legal issue and other issues on merit; that the ld. CIT(A) did not adjudicate the issue of jurisdiction of the issue of notice under section 148; and that the dismissal of the appeal ex-parte by the ld. CIT(A) is based on wrong appreciation of the facts

Late Krishna Gopal Gupta (Thr. Son and Legal Heir Shri Mahendra Kumar Gupta), Jaipur vs. I.T.O. Ward 2 (1), Jaipur

In the result, the appeal of the assesee is allowed

ITA 2/JPR/2024[A.Y. 2007-08]Status: DisposedITAT Jaipur14 Mar 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri G.M. Mehta, CAFor Respondent: Smt. Monisha Choudhary, Addl CIT-DR
Section 148Section 250

been held that- "We see no justifiable reason to interfere with the order under challenge. However, we clarify that when a notice under Section 148 of the Income tax Act is issued, the proper course 6 LATE KRISHAN GOPAL GUPTA VS ITO, WARD 2(1), JAIPUR of action ... assessee is non-est and liable to be quashed for which the ld. AR filed the following written submission. ‘’Brief facts of case: Notice under section 148 of IT Act was said to have been issued in this case on 11.03.2014 but was never received either by the assessee

M/S Concise Exim Pvt Ltd, Thane vs. ITO Ward 2 (1), Thane

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

ITA 3170/MUM/2023[2011-12]Status: DisposedITAT Mumbai13 Mar 2024AY 2011-12

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S Concise Exim Private Limited V. Income Tax Officer, Ward 2(1) Thane- 400614 B-426, 4Th Floor, Nbc Complex Plot No. 43, Sector- 11 Cbd Belapur, Thane- 400614 Pan: Aadcc5668A (Appellant) (Respondent) Assessee Represented By : None Department Represented By : Shri H.M. Bhatt

Section 148Section 250Section 68

much as he has not justified to uphold the action of the Ld. Assessing Officer in resorting the reassessment proceedings and issuing notice under section 148 of the Act since the notice issued under section 148 is bad in law. 2. That the order dated 11.07.2023 passed