“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

Reliable Vinimay (P) Ltd., Kolkata vs. ITO, Ward-4(1), Kolkata.

In the result, the appeal of the assessee stands allowed

ITA 695/KOL/2023[2011-12]Status: DisposedITAT Kolkata12 Mar 2024AY 2011-12

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No. 695/Kol/2023 Assessment Year: 2011-2012 Reliable Vinimay Private Limited,………..….Appellant Kaveri House, 132/1, Mahatma Gandhi Road, 5Th Floor, Kolkata-700001 [Pan:Aadcr7841N] -Vs.- Income Tax Officer,……………………………....Respondent Ward-7(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Manoj Kataruka, A.R. & Shri Rajeev Kumar Choudhury, Advocate, Appeared On Behalf Of The Assessee Shri B.K. Singh, Jcit Sr. Dr, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 13, 2023 Date Of Pronouncing The Order: March 12, 2024 O R D E R

Section 147Section 148Section 68

sanction order in the said case indicated non-application of mind to the reasons recorded by the Assessing Officer, the reopening notice under section 148 of the Income Tax Act was bad in law. 13. In view of the various decisions of the Hon’ble High Cours on the aforesaid ... Vinimay Private Limited given by the ld. Pr. CIT in this case in a mechanical manner without application of mind, therefore, the reopening notice under section 148 of the Income Tax Act was bad in law. The reopening of the assessment on this issue is also set aside

Bharath Hi-Tech Builders Pvt. Ltd., Bangalore vs. Dy. CIT, Circle-1(1)(2), Bangalore

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

ITA 1034/BANG/2023[2009-10]Status: DisposedITAT Bangalore11 Mar 2024AY 2009-10

Bench: Shri George George K, Vice- & Shri Laxmi Prasad Sahu

For Appellant: Sri.Inder Paul Bansal & Sri.Vivek BansalFor Respondent: Sri.Nilanjan Dey, Addl.CIT-DR

Section 147Section 148Section 151Section 153ASection 250

light of aforesaid legal position, it is an admitted position that the reasons for re-opening of the assessment by issuing of the notice under Section 148 of the Act were supplied to the appellant assessee. It is also admitted position that the appellant assessee after receipt of such reasons ... required respondent no.2 to satisfy himself as to whether it was a fit case in which sanction should be accorded for issuance of notice under section 148 of the Act and, thus, triggering the process of reassessment under section 147. The sanction- order passed by respondent no.2 simply contains

Dr. Arvind Taneja, New Delhi vs. ACIT Circle-61(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 9171/DEL/2019[2011-12]Status: DisposedITAT Delhi11 Mar 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Anubhav Sharmadr. Arvind Taneja, Vs. Acit, 75, Golf Links, Delhi Circle-61(1), New Delhi (Appellant) (Respondent) Pan:Aacpt0269N

For Appellant: Shri Bhupinder Jit Kumar, AdvFor Respondent: Shri Kanv Bali, Sr. DR

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

should not be allowed to contend that the assessment itself is invalid. Technically, the assessee did not file a return in response to notice under Section 148 and, therefore, it is not possible to compute the period of limitation for issue of the notice under Section 143(2) and this ... likewise in Sapthagiri Finance & Investments v. ITO [2012] 25 taxmann.com 341/210 Taxman 78 (Mad.) (Mag.). The facts of that case were that a notice under Section 148 of the Act was issued to the Assessee seeking to reopen the assessment for AY 2000-01. However, the Assessee did not file

Gandhinagar District Co.Op.Milk Producers Union Limited, Gandhinagar vs. The ACIT, Circle Gandhinaga, Gandhinagar

In the result, appeal of the assessee is allowed

ITA 512/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 Mar 2024AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Advocate & ShriFor Respondent: Dr. DArsi Suman Ratnam, CIT D.R. & Shri

Section 139(1)Section 143(3)Section 147Section 148Section 80PSection 80P(2)(c)Section 80P(2)(d)

escaped assessment and the case was reopened under Section 147 of the Act after obtaining the necessary approvals from the competent authority. A notice under Section 148 of the Act was issued and served upon the appellant and in response to the notice, the appellant filed the return of income ... amount of escapement of income chargeable to tax’: As per Clause (b) of sub-Section (1) of Section 149 of the Act, no notice under Section 148 shall be issued for an assessment year if four years, but not more than six years, have elapsed from the end of relevant

Lalwani Estates and Realtors Pvt Ltd, Manhar Villa, Anthony Road vs. ITO, 10 (2) (2), Aayekar Bhavan, Churchgate, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 3370/MUM/2023[2008-09]Status: DisposedITAT Mumbai08 Mar 2024AY 2008-09

Bench: Shri Narendra Kumar Choudhry, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 142(1)Section 143(1)Section 147Section 148

respect to accommodation entry received by the assessee during the year under consideration from various concerns operated by Mr. Pravin Kumar Jain Group. Notices under section 148 of the Act dated 30.03.2015 was issued and served on the assessee and procedures specified for re-assessment proceedings were duly completed ... Representative of the assessee submitted that the original return of income filed on 30.09.2008 to be treated as the return in response to notice under section 148 of the Act. The assessee was supplied with the copy of reasons for reopening of the assessment and Page No. 2 ITA NO.3370/MUM/2023

Smt. Surinder Kaur Thapar (Legal Heir of Late Shri Amrit Singh Thapar), New Delhi vs. Deputy Commissioner of Income Tax, Circle-2(1), New Delhi

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

ITA 2103/DEL/2023[2010-11]Status: DisposedITAT Delhi08 Mar 2024AY 2010-11

Bench: Shri Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2010-11 Smt. Surinder Kaur Thapar Vs. Dcit, (Legal Heir Of Late Shri Amrit Circle-2(1), Singh Thapar) New Delhi. R-612, New Rajinder Nagar, New Delhi – 110 060 Pan Aaapt0790Q (Appellant) (Respondent)

For Appellant: Shri Lalit Mohan, CA &For Respondent: Shri Piyush Tripathi, Sr. DR

Section 131Section 143(2)Section 143(3)Section 147Section 148Section 151(1)Section 234CSection 68Section 69Section 69C

commission and that the name of 2 Surinder Kaur Thapar vs. DCIT assessee also appears as one of the beneficiary of fictitious profit/loss, notice under section 148 of the Act dated 27.03.2017 was issued after obtaining approval under section 151(1) of the Act. In response thereto, the assessee submitted ... have heard the Ld. Representative of the parties and perused the records. The assessee, Shri Amrit Singh Thapar expired on 02.08.2020. Notice under section 148 of the Act was issued on 27.03.2017 and reassessment proceedings before the Ld. AO commenced by issue of statutory notice under section 143(2) served

Vijay Pal, Gurgaon vs. ITO, Gurgaon

In the result, appeals of the assessee are partly allowed as

ITA 3033/DEL/2017[2010-11]Status: DisposedITAT Delhi07 Mar 2024AY 2010-11

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.3033/Del/2017 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Vs. Ito, Vijay Pal, S/O Late Sh. Manohar Lal, Ward-4(4), Village & P.O. Nakhrola, Gurgaon. Tehsil Manesar, Gurgaon. Pan No.Anvpp7279G अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.3031/Del/2017 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Vs. Ito, Raj Singh, S/O Late Sh. Manohar Lal, Ward-3(3), Village & P.O. Nakhrola, Gurgaon. Tehsil Manesar, Gurgaon. Pan No.Bjdps1075G अपीलाथ" Appellant ""यथ"/Respondent अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.3032/Del/2017 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Vs. Ito Hariom, S/O Late Sh. Manohar Lal, Ward-2(1), Village & P.O. Nakhrola, Gurgaon. Tehsil Manesar, Gurgaon. Pan No.Afuph1298A अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 234ASection 54B

lacking jurisdiction. 18. The principle that the Assessing Officer alone who was holding the original jurisdiction over the assessee, who could issue notice under section 148 of the Act has been considered by the Hon’ble Punjab & Haryana High Court in the case of Lt. Col. Paramjeet Singh ... Income I.T.A. Nos. 3033, 3031 & 3032/Del/2017 Tax Officer, Ward 4(5) Gurgaon, has no jurisdiction over the assessees. In the circumstances, issue of notice under section 148 of the Act by the Income Tax Officer, Ward 3(4) Gurgaon and consequent assessment made under section 143(3) read with section

Hariom, Gurgaon vs. ITO, Gurgaon

In the result, appeals of the assessee are partly allowed as

ITA 3032/DEL/2017[2010-11]Status: DisposedITAT Delhi07 Mar 2024AY 2010-11

Section 143(3)Section 147Section 234ASection 54B

Raj Singh, Gurgaon vs. ITO, Gurgaon

In the result, appeals of the assessee are partly allowed as

ITA 3031/DEL/2017[2010-11]Status: DisposedITAT Delhi07 Mar 2024AY 2010-11

Section 143(3)Section 147Section 234ASection 54B

Ushaben Maganbhai Patel, Vadodara vs. The ITO, Ward-1(2)(5) Now Ward-1(2)(1), Vadodara

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

ITA 210/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad06 Mar 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2011-12

Section 139(1)Section 143(2)Section 147Section 148Section 250Section 50Section 54BSection 54FSection 69A

along with other three co- owners. Action under Section 147 of the Act was initiated in assessee’s case and notice under Section 148 of the Act dated 27.03.2018 was issued to the assessee. After taking approval from the PCIT in response to notice under Section 148

Abdul Samad, Chennai vs. ACIT, Central Circle -1(1), Chennai

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

ITA 661/CHNY/2023[2009-10]Status: DisposedITAT Chennai06 Mar 2024AY 2009-10

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.661/Chny/2023 िनधा"रण वष"/Assessment Year: 2009-10 Abdul Samad, Vs. The Assistant Commissioner Of 35, Chicken Market, Amman Koil Income Tax, Street, Broadway, Chennai 600 001. Central Circle 1(1), [Pan:Advpa3535G] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Fca ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 29.02.2024 घोषणा की तारीख /Date Of Pronouncement : 06.03.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-16, Chennai, Dated 29.03.2023 Relevant To The Assessment Year 2009-10. 2. Brief Facts Of The Case Are That The Assessee Has Filed His Return Of Income On 29.09.2009 Admitting Income At ₹.3,60,990/-. Subsequently, A Search & Seizure Operation Under Section 132 Of The Income Tax Act, 1961 [“Act” In Short] Was Carried Out In The Case Of M/S. S.S. Hyderabad Biryani Pvt. Ltd., Old No. 35, 1St Floor, Amman Koil Street, Near Chicken

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri AR V Sreenivasan, Addl. CIT

Section 132Section 142(1)Section 144Section 148

Officer has noticed that in the case of the assessee, the income has escaped assessment for the assessment year 2009-10 and a notice under section 148 of the Act was issued after recording the reasons for reopening of assessment. The assessee, has not filed the return of income ... response to notice under section 148 of the Act nor furnished any reply to the notices issued under section 142(1) of the Act. Therefore, the Assessing Officer proposed to show-cause the assessee as to why the assessment should not be completed under section

Balasingam Somasundaram, Coimbatore vs. ACIT, Central Circle 1, Coimbatore

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

ITA 1200/CHNY/2023[2014-15]Status: DisposedITAT Chennai06 Mar 2024AY 2014-15

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri P.Sajit Kumar, JCIT

Section 133ASection 143(2)Section 148Section 250Section 271ASection 271BSection 44A

assessee deposited cash to the tune of Rs. 7,83,18,750/- and also invested a sum of Rs. 60,33,000/-. Therefore, notice under section 148 of the Act was issued to the assessee for assessing the escaped income. The assessee in response, filed the return of income

Balasingam Somasundaram, Coimbatore vs. ACIT, Central Circle 1, Coimbatore

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

ITA 1199/CHNY/2023[2013-14]Status: DisposedITAT Chennai06 Mar 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri P.Sajit Kumar, JCIT

Section 133ASection 143(2)Section 148Section 250Section 271ASection 271BSection 44A

Gopal Lal Meena, Jaipur vs. DCIT, Circle-7, Jaipur

In the result, the appeal of the assessee is allowed

ITA 400/JPR/2023[2013-14]Status: DisposedITAT Jaipur06 Mar 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Vishnu Khandelwal (CA)For Respondent: Sh. A. S, Nehra (Addl. CIT)

Section 142(1)Section 143(2)Section 147Section 148Section 151Section 50CSection 53(2)Section 53C

holding that director of CBDT being above the rank of Joint Commissioner of Income Tax was competent to accord sanction for issuance of notice under section 148 of the income Tax Act as per provisions of section 151. 2. That in the facts and circumstances of the case, the learned ... Appeal) has erred in not holding the issuance of notice under section 148 as unlawful having been issued without sanction of authority as mentioned in section 151 of the income tax Act 1961. 3. That in the facts and circumstances of the case the learned CIT (A) has erred

Income Tax Officer, Ward-1(2), Jaipur vs. Mukesh Kumar Soni, Jaipur

In the result appeal of the revenue is dismissed and the cross

ITA 656/JPR/2023[2018-19]Status: DisposedITAT Jaipur04 Mar 2024AY 2018-19

Bench: Moving Towards The Facts Of The Case We Would Like To Mention

For Appellant: Sh. S. B. Natani (FCA)For Respondent: Sh. Arvind Kumar (CIT)

Section 143(1)Section 143(3)Section 144BSection 147Section 148A

examining the case thoroughly that assessment was completed on returned income. (B) Proceeding under section 148A/148 In this case the learned AO issued notice under section 148 after issuing notice under section 148A(b) and passing order under section 148 A(d). Notice under section 148 has been issued ... circumstances of the case the learned CIT Appeals (NFAC) erred in not quashing the proceedings under section 147/148 as the grounds on which notice under section 148(A)(b) was issued and order under section 148A(d) was passed and notice under section 148 was issued did not survive

Upinder Kaur Khalsa Rao, Mumbai vs. Income Tax Officer 35(3)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3670/MUM/2023[2011-12]Status: DisposedITAT Mumbai04 Mar 2024AY 2011-12

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Haridas Bhat, CAFor Respondent: 27.02.2024

Section 148Section 2(24)

amount received by the assessee from the developer has escaped assessment, and accordingly the AO re-opened the assessment by issue of notice under section 148 of the Income Tax Act (the Act). The assessee in response to notice under section 148 filed a return of income on 14.11.2018 declaring ... 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

Dy. Commissioner of Income Tax, Circle-1, Nellore vs. Gopisetty Satyanarayana, Nellore

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

ITA 652/HYD/2019[2010-11]Status: DisposedITAT Hyderabad29 Feb 2024AY 2010-11

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyनिर्धारण आ.अपी.सं अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. Appellant Respondent / Ita No. Gopisetty Deputy Commissioner Satyanarayana, Of Income Tax, 2010-11 441/Hyd/2019 Nellore Circle-1, [Pan: Aiipg4150B] Nellore Deputy Commissioner Gopisetty Of Income Tax, Satyanarayana, 652/Hyd/2019 2010-11 Circle-1, Nellore Nellore [Pan: Aiipg4150B] निर्धाररती द्वधरध/Assessee By: Shri K.A. Sai Prasad, Ar रधजस्‍व द्वधरध/Revenue By: Shri Waseem Ur Rehman, Dr सुिवधई की तधरीख/Date Of Hearing: 28/02/2024 घोर्णध की तधरीख/Pronouncement On: 29/02/2024 आदेश / Order Per K. Narasimha Chary, J.M: Aggrieved By The Order(S) Passed By The Learned Commissioner Of Income Tax (Appeals)-Tirupati (“Learned Cit(A)”), In The Case Sri G. Satyanarayana (“The Assessee”) For The Assessment Year 2010-11, Both Assessee & Revenue Preferred These Appeals. For The Sake Of Convenience, These Appeals Are Decided By This Common Order.

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri Waseem UR Rehman, DR

Section 133ASection 143(1)Section 147Section 148Section 69

survey under section 133A of the Act on 24/11/2011, proceedings under section 147 of the Act were taken up by issuing notice under section 148 of the Act. Basing on the material impounded during the survey, learned Assessing Officer called upon the assessee to explain the sources for the advances

Gopisetty Satyanarayana, Nellore vs. Dy. Commissioner of Income Tax, Circle-1, Nellore

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

ITA 441/HYD/2019[2010-11]Status: DisposedITAT Hyderabad29 Feb 2024AY 2010-11

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri Waseem UR Rehman, DR

Section 133ASection 143(1)Section 147Section 148Section 69

Truevalue Projects Private Limited, Mumbai vs. Deputy Commissioner of Income Tax-Circle 1(3)(2), Mumbai

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

ITA 3756/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Feb 2024AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Dy. Cit Truevalue Projects Private Circle 1(3)(2) Limited Aaykar Bhavan Office No.Ii-B, Mezzanine Floor, Vs. 289 Emca House, S.B.S Road, Maharshi Karve Road, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aacct5333Q Assessee By : Ms. Rekha Pandey, Ar Revenue By : Shri P.D. Chougule, Dr Date Of Hearing: 29.02.2024 Date Of Pronouncement : 29.02.2024

For Appellant: Ms. Rekha Pandey, ARFor Respondent: Shri P.D. Chougule, DR

Section 132Section 133(6)Section 143(3)Section 147Section 148Section 68

True value Projects Private Limited; A.Y. 2012-13 assessee to furnish certain information which was not furnished. Therefore, the reasons were recorded and notice under Section 148 of the Act was issued on 30th March, 2018. The assessee filed return of income on 16th April, 2019. On 23rd October

Simcorp Fund Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle- 4(3), Mumbai

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

ITA 3340/MUM/2023[2005-06]Status: DisposedITAT Mumbai29 Feb 2024AY 2005-06

Bench: Shri Br Baskaran, Am & Shri Aby T. Varkey, Jm

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Nayanjyoti Nath, DR

Section 143(3)Section 144Section 147Section 148Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI BR BASKARAN, AM & SHRI ABY T. VARKEY, JM STaHX