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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

Crosseas Capital Services Private Ltd, Mumbai vs. ACIT(Central)-2(4), Mumbai

In the result, all the four appeals filed by the assessee are hereby partly allowed

ITA 3420/MUM/2023[2018-19]Status: DisposedITAT Mumbai26 Feb 2024AY 2018-19

Bench: Shri Amit Shukla & Shri Amarjit Singhassessment Year: 2015-16 Assessment Year: 2014-15 Assessment Year: 2020-21 Assessment Year: 2018-19 M/S. Crosseas Capital Assistant Commissioenr Of Services P. Ltd., Income Tax (Central Suite 37, 5Th Floor, Circle)-2(4), Martin Burn House, Vs. 802, 8Th Floor, 1 Rn Mukherjee Road, Pratishtha Bhavan, Kolkata, Old Cgo Annexe, West Bengal - 700 001 Maharishi Karve Road, Pan: Aaccc5470H Mumbai – 400 020 (Appellant) (Respondent) Present For: Assessee By : Shri Firoze B. Andhyarujina , A.R. & Shri Maneck Andhyarujina, Ar. Revenue By : Shri H.M. Bhatt, D.R. Date Of Hearing : 06.02.2024 Date Of Pronouncement : 26.02.2024 O R D E R Per Bench : All These Four Appeals Are Filed By The Assessee Against The Different Orders Of Commissioner Of Income Tax Passed Under Section 250 Of The Act Pertaining To Assessment Year 2018-19 &

For Appellant: Shri Firoze B. Andhyarujina , A.R. &For Respondent: Shri H.M. Bhatt, D.R
Section 234BSection 250Section 37(1)

completed on 29.12.2016 and total income was assessed at Rs.3,62,29,900/-. Subsequently the assessment was reopened vide issuing of notice under section 148 of the Act on 05.03.2021. The assessment was reopened on the basis of information received from DGIT (Investigation) that an amount of Rs.66.2 lakhs ... perused the above referred decision of the Hon’ble Jurisdictional High Court of Bombay wherein it was held that if after issuing a notice under section 148 the AO accepts the contention of the assessee and holds that income for which he had initially formed a reason to believe that

Crosseas Capital Services Private Limited, Mumbai vs. Assistant Commissioner of Income Tax (Central)-2(4), Mumbai

In the result, the appeal of the assessee in ITA

ITA 3419/MUM/2023[2020-21]Status: DisposedITAT Mumbai26 Feb 2024AY 2020-21

Bench: Shri Amit Shukla & Shri Amarjit Singh

Section 234BSection 250Section 37(1)

completed on 29.12.2016 and total income was assessed at Rs.3,62,29,900/-. Subsequently the assessment was reopened vide issuing of notice under section 148 of the Act on 05.03.2021. The assessment was reopened on the basis of information received from DGIT (Investigation) that an amount of Rs.66.2 lakhs ... perused the above referred decision of the Hon'ble Jurisdictional High Court of Bombay wherein it was held that if after issuing a notice under section 148 the AO accepts the contention of the assessee and holds that income for which he had initially formed a reason to believe that

Crosseas Capital Services Pvt Ltd, Mumbai vs. ACIT (Central-2(4), Mumba

In the result, all the four appeals filed by the assessee are hereby partly allowed

ITA 3418/MUM/2023[2014-2015]Status: DisposedITAT Mumbai26 Feb 2024AY 2014-2015

Bench: Shri Amit Shukla & Shri Amarjit Singhassessment Year: 2015-16 Assessment Year: 2014-15 Assessment Year: 2020-21 Assessment Year: 2018-19 M/S. Crosseas Capital Assistant Commissioenr Of Services P. Ltd., Income Tax (Central Suite 37, 5Th Floor, Circle)-2(4), Martin Burn House, Vs. 802, 8Th Floor, 1 Rn Mukherjee Road, Pratishtha Bhavan, Kolkata, Old Cgo Annexe, West Bengal - 700 001 Maharishi Karve Road, Pan: Aaccc5470H Mumbai – 400 020 (Appellant) (Respondent) Present For: Assessee By : Shri Firoze B. Andhyarujina , A.R. & Shri Maneck Andhyarujina, Ar. Revenue By : Shri H.M. Bhatt, D.R. Date Of Hearing : 06.02.2024 Date Of Pronouncement : 26.02.2024 O R D E R Per Bench : All These Four Appeals Are Filed By The Assessee Against The Different Orders Of Commissioner Of Income Tax Passed Under Section 250 Of The Act Pertaining To Assessment Year 2018-19 &

For Appellant: Shri Firoze B. Andhyarujina , A.R. &For Respondent: Shri H.M. Bhatt, D.R
Section 234BSection 250Section 37(1)

completed on 29.12.2016 and total income was assessed at Rs.3,62,29,900/-. Subsequently the assessment was reopened vide issuing of notice under section 148 of the Act on 05.03.2021. The assessment was reopened on the basis of information received from DGIT (Investigation) that an amount of Rs.66.2 lakhs ... perused the above referred decision of the Hon’ble Jurisdictional High Court of Bombay wherein it was held that if after issuing a notice under section 148 the AO accepts the contention of the assessee and holds that income for which he had initially formed a reason to believe that

Crosseas Capital Services Private Limited, Mumbai vs. ACIT (Central -2(4), Mumbai

In the result, the appeal of the assessee in ITA

ITA 3417/MUM/2023[2015-16]Status: DisposedITAT Mumbai26 Feb 2024AY 2015-16

Bench: Shri Amit Shukla & Shri Amarjit Singh

For Appellant: Shri Firoze B. Andhyarujina, A.R. &For Respondent: Shri H.M. Bhatt, D.R
Section 234BSection 250Section 37(1)

completed on 29.12.2016 and total income was assessed at Rs.3,62,29,900/-. Subsequently the assessment was reopened vide issuing of notice under section 148 of the Act on 05.03.2021. The assessment was reopened on the basis of information received from DGIT (Investigation) that an amount of Rs.66.2 lakhs ... perused the above referred decision of the Hon'ble Jurisdictional High Court of Bombay wherein it was held that if after issuing a notice under section 148 the AO accepts the contention of the assessee and holds that income for which he had initially formed a reason to believe that

Shanno Mohammed Yusuf Warsi, Mumbai vs. Income Tax Officer-25(1)(3), Mumbai

In the result, the appeal

ITA 1306/MUM/2023[2013-2014]Status: DisposedITAT Mumbai26 Feb 2024AY 2013-2014

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

For Appellant: Mr. Pankaj SoniFor Respondent: Mr. Manoj Kumar Singh, Sr. DR
Section 147Section 68Section 69C

income the Assessing Officer recorded reasons to believe that income the Assessing Officer recorded reasons to believe that income escaped assessment and issued notice under section 148 of the escaped assessment and issued notice under section 148 of the escaped assessment and issued notice under section 148 of the Shanno ... carried out any invest has not carried out any investigation prior to record reasons and igation prior to record reasons and issue of notice under section 148 of the A otice under section 148 of the Act is concerned, we are of ct is concerned, we are of the opinion

Smt. Varshaben Paras Jani(L.H. of Shri Paras Chunilal Jani), Ahmedabad vs. ACIT, Circle-5(1), Ahmedabad

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

ITA 536/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad23 Feb 2024AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 536/Ahd/2019 ("नधा"रण वष" / Assessment Year : 2012-13)

For Respondent: Shri Sudhendu Das, CIT. DR
Section 143(3)Section 148Section 292B

filing a voluntary return for escapement of income and the only provision under which return can be filed is on issue of a notice under Section 148. Indisputably, the assessment proceedings for escaped income were initiated by issue of notice under Section 148 of the Act and therefore ... cardinal proposition in law that not issuing notice at all or issuing that beyond statutory period or issue of an invalid notice under Section 148 does affect the jurisdiction of AO and would make the assessment/reassessment "null and void" because the notice under this section is not a mere procedural

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 209/CHNY/2020[2010-11]Status: DisposedITAT Chennai23 Feb 2024AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment ITA Nos.207 to 209/Chny/2020 year. The same view ... opinion, we have to see the law prevailing on the date of issue of the notice under Section 148, i.e., November 20, 1998. Admittedly, by that date, the new Section 147 has come into force and, hence, in our opinion, it is the new Section 147 which will apply

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 208/CHNY/2020[2009-10]Status: DisposedITAT Chennai23 Feb 2024AY 2009-10

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment ITA Nos.207 to 209/Chny/2020 year. The same view ... opinion, we have to see the law prevailing on the date of issue of the notice under Section 148, i.e., November 20, 1998. Admittedly, by that date, the new Section 147 has come into force and, hence, in our opinion, it is the new Section 147 which will apply

ACIT, CC - I (2), Chennai vs. M/S. Balaji Hotels & Enterprises Ltd., Chennai

In the result, the appeals filed by the Revenue in ITA Nos

ITA 207/CHNY/2020[2008-09]Status: DisposedITAT Chennai23 Feb 2024AY 2008-09

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment ITA Nos.207 to 209/Chny/2020 year. The same view ... opinion, we have to see the law prevailing on the date of issue of the notice under Section 148, i.e., November 20, 1998. Admittedly, by that date, the new Section 147 has come into force and, hence, in our opinion, it is the new Section 147 which will apply

DCIT Central Circle -2(2), Mumbai vs. Shri Viral Saraf Mittal, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1843/MUM/2022[2018-19]Status: DisposedITAT Mumbai23 Feb 2024AY 2018-19

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit – Central Circle – 2(2) V. Viral Saraf Mittal Room No. 806, 8Th Floor 901/902, Capri Heights Old Cgo Annex Building Palli Hill, Bandra (W) M.K. Road, Mumbai - 400020 Mumbai - 400050 Pan: Azbps0317C (Appellant) (Respondent) Assessee Represented By : Shri Sidharth Kothari Department Represented By : Ms. Kavitha Kaushik

Section 10(38)Section 143(2)Section 68

Aroni Commercials Ltd. (supra), has to be tested/examined only on the basis of the reasons recorded at the time of issuing a notice under section 148 of the Act seeking to reopen an assessment. These reasons cannot be improved upon and/or supplemented much less substituted by affidavit and/or oral submissions

Savla Buildwell LLP, Mumbai vs. National Faceless Appeal Centre, Delhi

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

ITA 2066/MUM/2022[2013-14]Status: DisposedITAT Mumbai22 Feb 2024AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Prateek JainFor Respondent: Shri Manoj Kumar Singh
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 254(1)Section 68

assessee is one of the beneficiaries of accommodation entries for unsecured loan, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 27/03/2017. Upon verification of the details furnished during the assessment proceedings, it was observed that the assessee

M/S. Palan Real Estate Developers Pvt.Ltd., Ahmedabad vs. The Income Tax Officer, Ward-3(1)(1), Ahmedabad

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

ITA 827/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2010-11

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 827/Ahd/2023 ("नधा"रण वष" / Assessment Year : 2010-11)

For Respondent: Shri V. K. Mangla, Sr. DR
Section 132Section 143(3)Section 148Section 151Section 68

Assessing Officer on various grounds. One of the grounds raised by the assessee is that the approval to reopen the assessment and issue notice under Section 148 of the Act was given to the Assessing Officer by the Principal Commissioner of Income-tax in a mechanical manner and without application ... placed at page No. 42 to point out that the proposal submitted by the Assessing Officer to reopen the assessment and issue notice under Section 148 of the Act to the assessee was approved by the learned Principal Commissioner of Income-tax by recording only one word “yes”. He contended

Nandkumar Namdeorao Diwate, Kolhapur vs. The Income Tax Officer, Ward-1(1), Kolhapur

In the result, the appeal of the assessee is allowed

ITA 1161/PUN/2023[2011-12]Status: DisposedITAT Pune21 Feb 2024AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.1161/Pun/2023 Assessment Year : 2011-12 Nandkumar Namdeorao Diwate, Vs. Ito, Ward-1(1), 492, C-Ward, Kolhapur Opp. Main Rajaram Highschool, Juna Rajwada, Karveer, Kolhapur, Maharashtra-416001 Pan : Aeqpd 1603L Appellant Respondent

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Ramnath P. Murkunde
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 69

adopted the principle that where the Assessing Officer has formed a reason to believe that income has escaped assessment and has issued a notice under section 148 on certain specific issues, it was not open to him during the course of the proceedings for assessment or reassessment to assess ... reassess any other income, which may have escaped assessment but which did not form the subject-matter of the notice under section 148. This view was adopted in the Judgment of the Punjab and Haryana High Court in Vipan Khanna's case (supra) and in the judgment of the Kerala

Deputy Commissioner of Income Tax, Central Circle- 1(4), Chennai vs. Shriram Chits Private Limited, Hyderabad

ITA 953/CHNY/2023[2018-19]Status: DisposedITAT Chennai21 Feb 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

Section 143(1)Section 148Section 14A

return was processed under section 143(1) of the Income Tax Act, 1961 [“Act” in short]. Subsequently, notice under section 148 of the Act dated 23.01.2018 was issued and served on the assessee. Notices under sections 142(1) and 143(2) of the Act were issued and served upon

Deputy Commissioner of Income Tax, Central Circle 1(4), Chennai vs. Shriram Chits Private Limited, Hyderabad

ITA 945/CHNY/2023[2020-21]Status: DisposedITAT Chennai21 Feb 2024AY 2020-21

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

Section 143(1)Section 148Section 14A

return was processed under section 143(1) of the Income Tax Act, 1961 [“Act” in short]. Subsequently, notice under section 148 of the Act dated 23.01.2018 was issued and served on the assessee. Notices under sections 142(1) and 143(2) of the Act were issued and served upon

Deputy Commissioner of Income Tax, Central Circle 1(4), Chennai vs. Shriram Chits Private Limited, Hyderabad

ITA 944/CHNY/2023[2018-19]Status: DisposedITAT Chennai21 Feb 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

Section 143(1)Section 148Section 14A

return was processed under section 143(1) of the Income Tax Act, 1961 [“Act” in short]. Subsequently, notice under section 148 of the Act dated 23.01.2018 was issued and served on the assessee. Notices under sections 142(1) and 143(2) of the Act were issued and served upon

Deputy Commissioner of Income Tax, Central Circle 1(4), Chennai vs. Shriram Chits Private Limited, Hyderabad

ITA 943/CHNY/2023[2017-18]Status: DisposedITAT Chennai21 Feb 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

Section 143(1)Section 148Section 14A

return was processed under section 143(1) of the Income Tax Act, 1961 [“Act” in short]. Subsequently, notice under section 148 of the Act dated 23.01.2018 was issued and served on the assessee. Notices under sections 142(1) and 143(2) of the Act were issued and served upon

Deputy Commissioner of Income Tax, Central Circle 1(4), Chennai vs. Shriram Chits Private Limited, Hyderabad

ITA 942/CHNY/2023[2015-16]Status: DisposedITAT Chennai21 Feb 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

Section 143(1)Section 148Section 14A

return was processed under section 143(1) of the Income Tax Act, 1961 [“Act” in short]. Subsequently, notice under section 148 of the Act dated 23.01.2018 was issued and served on the assessee. Notices under sections 142(1) and 143(2) of the Act were issued and served upon

M/S Ratnadeep Multitrade Private Limited, Mumbai vs. Income Tax Department, NFAC, Mumbai

In the result, the appeal by the assessee is allowed

ITA 3561/MUM/2023[2013-14]Status: DisposedITAT Mumbai21 Feb 2024AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Ravikant S. PathakFor Respondent: Smt. Mahita Nair
Section 143(3)Section 144BSection 147Section 148Section 250Section 4

which was accepted, and Form 5 was issued on 03/03/2022 by the learned PCIT. 4. It is further submitted that meanwhile, notice under section 148 of the Act was issued and an assessment order under section 144B r/w section 147 of the Act was passed on 30/03/2022. In further appeal

Vanpool Consulting and Advisory Pvt Ltd., Mumbai vs. DCIT, CC-1(2), Mumbai

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

ITA 2068/MUM/2023[2012-13]Status: DisposedITAT Mumbai21 Feb 2024AY 2012-13

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blevanpool Consulting & Advisory Pvt., Ltd., V. Dcit – Cc – 1(2) 1501, Orient Height Room No. 906, Ninth Floor Rajaram Mohanrai Road Pratishtha Building, M.K. Road Grant Road (E), Mumbai - 400004 Mumbai - 400020 Pan: Aaacv2355C (Appellant) (Respondent) Assessee Represented By : Shri P.V. Desai Department Represented By : Ms. Kavitha Kaushik

Section 143(3)Section 144Section 147Section 148Section 153C

true and full facts and hence Assessing Officer re-opened the assessment for A.Y.2012-13 under section 147 of the Act. Accordingly, he issued notice under section 148 of the Act dated 30.03.2019 and served on the assessee. Page 3 of 13 Vanpool Consulting and Advisory Pvt., Ltd., 5. The assessee ... submissions in e-portal. Therefore, the observations of the tax authorities that assessee has not filed any return of income in response to notice under section 148 of the Act is not correct. Further, he submitted that the reasons recorded for reopening the assessment was never forwarded to the assessee