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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

Ravindra K Reshamwala, Mumbai vs. The Income Tax Officer Ward 17(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 2925/MUM/2023[2010-11]Status: DisposedITAT Mumbai29 Dec 2023AY 2010-11

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

For Appellant: Shri Piyush ChhajedFor Respondent: Smt. Mahita Nair
Section 143(1)Section 143(3)Section 147Section 148Section 151(2)Section 250Section 35Section 35A

beneficiaries who has claimed deduction of the donation made to Navjeevan Charitable Trust, proceedings under section 147 of the Act were initiated and notice under section 148 of the Act was issued on 24/03/2017. During the reassessment proceedings, the assessee was Ravindra K. Reshamwala ITA no.2925/Mum./2023 asked to show

Omkar Metal and Alloys Corporation, C P Tank Mumbai vs. Income Tax Officer 19. 2. 4, Matru Mandir

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

ITA 2838/MUM/2023[2009-2010]Status: DisposedITAT Mumbai29 Dec 2023AY 2009-2010

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2009-10 Omkar Metal & Alloys Ito 19.2.4, Corporation, C P Tank Matru Mandir, Opp Bhatia Room No. 47, Balakrishna Vs. Hospital, Grant Road (West), Niwas, 2Nd Floor, 2Nd Mumbai-400007. Panjarapole Lane, Mumbai-400004. Pan No. Aaafo 4997 N Appellant Respondent

For Appellant: Mr. Vimal PunmiyaFor Respondent: Mr. H.M. Bhatt, Sr. DR
Section 143(3)Section 145(3)Section 147Section 148

issuing notice ng proceeding under section 147 of the Act by issuing notice ng proceeding under section 147 of the Act by issuing notice under section 148 of the Act in as much as reasons recorded by under section 148 of the Act in as much as reasons recorded

Dr Batras Positive Health Clinic Private Limited, Mumbai vs. CIT(A), National Faceless Appeal Centre

In the result, all the appeals of the assessee

ITA 2748/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 Dec 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Ita Nos. 2748, 2747 & 2761/Mum/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dr Batras Positive Health Clinic Cit(A), National Faceless Pvt. Ltd., Appeal Centre, Delhi. 2Nd Floor, H Kantilal Compound, Vs. Andheri Kurla Road, Sakinaka Andheri East-400072 Pan No. Aabcd 3857 G Appellant Respondent

For Appellant: Mr. Yogesh A. Thar, Mr. ChaitanyaFor Respondent: Mr. Ashok Kumar Ambastha, Sr
Section 143(2)Section 147Section 16(2)

four years from the relevant 13 and four years from the relevant assessment year expire assessment year expired on 31/03/2017, whereas , whereas notice under section 148 of the A e Act has been issued to the assessee on ct has been issued to the assessee on 26/03/2018. The learned counsel

Dr Batras Positive Health Clinic Private Limited, Mumbai vs. CIT(A), NFAC, National Faceless Appeal Centre

In the result, all the appeals of the assessee

ITA 2747/MUM/2023[AY 2012-13]Status: DisposedITAT Mumbai29 Dec 2023

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Ita Nos. 2748, 2747 & 2761/Mum/2023 Assessment Year: 2011-12, 2012-13 & 2013-14 Dr Batras Positive Health Clinic Cit(A), National Faceless Pvt. Ltd., Appeal Centre, Delhi. 2Nd Floor, H Kantilal Compound, Vs. Andheri Kurla Road, Sakinaka Andheri East-400072 Pan No. Aabcd 3857 G Appellant Respondent

For Appellant: Mr. Yogesh A. Thar, Mr. ChaitanyaFor Respondent: Mr. Ashok Kumar Ambastha, Sr
Section 143(2)Section 147Section 16(2)

four years from the relevant 13 and four years from the relevant assessment year expire assessment year expired on 31/03/2017, whereas , whereas notice under section 148 of the A e Act has been issued to the assessee on ct has been issued to the assessee on 26/03/2018. The learned counsel

+DCIT CC- 7(2), Mumbai vs. Sahebrao Deshmukh Co.Op. Bank Ltd., Mumbai

Accordingly, Ground No. 1 and 2 raised by the Revenue are dismissed, while Ground No

ITA 2478/MUM/2021[2014-15]Status: DisposedITAT Mumbai29 Dec 2023AY 2014-15

Bench: The Tribunal.

For Appellant: Shri Satish ModiFor Respondent: Ms. Shreekala Pardeshi
Section 143(3)Section 147Section 148

Whether on the facts and the circumstances of the case and in law, the Ld CIT(A) has erred in deciding that the notice under section 148 of the Act is void ab initio and hence passed is null and void. 3. Whether on the facts and the circumstances ... Despite this, the revenue audit objection merely stated that deduction claimed by the Assessee should have been disallowed. The Assessing Officer also issued notice under Section 148 of the Act without application of mind and without providing any basis or reasoning by merely placing reliance on the audit objection

Suni Davis Thakolkkaran, Surat vs. Income Tax Officer, Ward-2(3)(6), Surat

In the result, appeal of assessee is dismissed

ITA 548/SRT/2023[2011-12]Status: DisposedITAT Surat29 Dec 2023AY 2011-12

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.548/Srt/2023 (Ay 2011-12) (Hearing In Physical Court) Suni Davis Thakolkkaran Income Tax Officer, Ward- A-35, Narayan Park, Hazira 2(3)(6), Surat, 4Th Floor, Vs Main Road, Ichhapore, Surat- Aayakar Bhavan, Anavil 394510 Business Centre, Adajan- Pan : Adhpt 7419 G Hazira Road, Surat-395009 अपीलाथ"/Appellant ""थ" /Respondent

Section 131Section 143(1)Section 147Section 148Section 254(1)

recording reasons that income of assessee to the extent of credit in the bank account at Rs.88,66,961/- has escaped assessment. Further Notice under section 148 was issued to the assessee. The assessee in response filed return of income on 09.05.2018 declaring same income as declared initially. The Assessing

Shrifal Impex Private Limited, Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 250/SRT/2023[2014-15]Status: DisposedITAT Surat29 Dec 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

prescribed format. It was only after perusing such details that the Assistant Commissioner agreed that it was a fit case for issuing notice under Section 148 of the Act. Thus, this is not a case where such permission can be stated to have been granted without application of mind ... reference. "12. So far as submission of learned counsel for petitioners that there was no proper sanction/approval on the date of issuance of notice under section 148 of the Act of 1961 is concerned, provision under section 151 of the Act of 1961 provides for "sanction for issuance of notice

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 191/SRT/2023[2012-13]Status: DisposedITAT Surat29 Dec 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

prescribed format. It was only after perusing such details that the Assistant Commissioner agreed that it was a fit case for issuing notice under Section 148 of the Act. Thus, this is not a case where such permission can be stated to have been granted without application of mind ... reference. "12. So far as submission of learned counsel for petitioners that there was no proper sanction/approval on the date of issuance of notice under section 148 of the Act of 1961 is concerned, provision under section 151 of the Act of 1961 provides for "sanction for issuance of notice

Shrifal Impex Pvt. Ltd., Surat vs. Income Tax Officer, Ward - 2(1)(3), Surat

ITA 190/SRT/2023[2011-12]Status: DisposedITAT Surat29 Dec 2023AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

Section 143(3)Section 148

prescribed format. It was only after perusing such details that the Assistant Commissioner agreed that it was a fit case for issuing notice under Section 148 of the Act. Thus, this is not a case where such permission can be stated to have been granted without application of mind ... reference. "12. So far as submission of learned counsel for petitioners that there was no proper sanction/approval on the date of issuance of notice under section 148 of the Act of 1961 is concerned, provision under section 151 of the Act of 1961 provides for "sanction for issuance of notice

DCIT, Vapi vs. Gujarart Polysol Chemical Ltd, Vapi

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

ITA 595/SRT/2023[2018-19]Status: DisposedITAT Surat28 Dec 2023AY 2018-19

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

Section 147Section 148Section 156Section 254(1)Section 270A

competent authority reopened the case of assessee under section 147. The assessing officer passed order under section 148A on 31.03.2022 and issued notice under section 148 on the same day. In response to the notice under section 148 the assessee filed its reply on 29.04.2022. During the course of assessment

Gujarat Polysol Chemicals Limited Limited, Vapi vs. The Asst. Commissioner of Income Tax, Central Circle-1, Vapi

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

ITA 513/SRT/2023[2018-19]Status: DisposedITAT Surat28 Dec 2023AY 2018-19

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

Section 147Section 148Section 156Section 254(1)Section 270A

competent authority reopened the case of assessee under section 147. The assessing officer passed order under section 148A on 31.03.2022 and issued notice under section 148 on the same day. In response to the notice under section 148 the assessee filed its reply on 29.04.2022. During the course of assessment

Pravin Shrawanlal Sahu, Nagpur vs. Assessing Officer, NFAC, Delhi

In the result, appeal of the assessee in ITA

ITA 200/NAG/2023[2015-16]Status: DisposedITAT Nagpur27 Dec 2023AY 2015-16

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.199 & 200/Nag/2023 िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16 Pravin Shrawanlal Sahu, The Assessing Officer- Plot No.517, Sahu Bhawan, V Nfac. Chandabai Layout, Chandan S Nagar, Medical Square, Nagpur – 440009. Pan: Bbmps2413P Appellant / Assessee Respondent / Revenue Assessee By Shri Kapil Hirani – Ca Revenue By Shri Abhay Y. Marathe – Sr.Dr Date Of Hearing 29/11/2023 Date Of Pronouncement 27/12/2023

Section 139Section 142(1)Section 147Section 148Section 250

Assessing Officer(AO) received information regarding cash deposits by the assessee. Accordingly, after recording reasons as per law, AO issued notice under section 148 of the Act dated 24.03.2021. However, assessee had not filed Return of Income in response to notice under section 148 of the Act. Subsequently, AO issued ... case : 10. No Return of Income has been filed by the assessee under section 139 of the Act and in response to notice under section 148 of the Act. There were cash deposits of Rs.1,34,67,675/- in the Bank Account No.0432053000002025 of South Indian Bank, Nagpur during

Pravin Shrawanlal Sahu, Nagpur vs. Assessing Officer, NFAC, New Delhi

In the result, appeal of the assessee in ITA

ITA 199/NAG/2023[2014-15]Status: DisposedITAT Nagpur27 Dec 2023AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.199 & 200/Nag/2023 िनधा"रण वष" / Assessment Years : 2014-15 & 2015-16 Pravin Shrawanlal Sahu, The Assessing Officer- Plot No.517, Sahu Bhawan, V Nfac. Chandabai Layout, Chandan S Nagar, Medical Square, Nagpur – 440009. Pan: Bbmps2413P Appellant / Assessee Respondent / Revenue Assessee By Shri Kapil Hirani – Ca Revenue By Shri Abhay Y. Marathe – Sr.Dr Date Of Hearing 29/11/2023 Date Of Pronouncement 27/12/2023

Section 139Section 142(1)Section 147Section 148Section 250

Assessing Officer(AO) received information regarding cash deposits by the assessee. Accordingly, after recording reasons as per law, AO issued notice under section 148 of the Act dated 24.03.2021. However, assessee had not filed Return of Income in response to notice under section 148 of the Act. Subsequently, AO issued ... case : 10. No Return of Income has been filed by the assessee under section 139 of the Act and in response to notice under section 148 of the Act. There were cash deposits of Rs.1,34,67,675/- in the Bank Account No.0432053000002025 of South Indian Bank, Nagpur during

Assistant Commissioner of Income Tax Chandrapur Circle, Chandrapur vs. M/S Chadda Transport, Chandrapur

Appeal is dismissed

ITA 363/NAG/2019[2009-10]Status: DisposedITAT Nagpur27 Dec 2023AY 2009-10

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.363/Nag/2019 िनधा"रण वष" / Assessment Year : 2009-10 The Assistant M/S.Chadda Transport, Commissioner Of V Kosara Road, Padoli, Income Tax, S Chandrapur, Chandrapur Circle, Maharashtra – 442401. Chandrapur. Pan: Aaafc8556F Appellant / Revenue Respondent / Assessee Cross Objection No.01/Nag/2020 (Arising Out Of Ita No.363/Nag/2019) िनधा"रण वष" / Assessment Year : 2009-10 M/S.Chadda Transport, The Assistant Kosara Road, Padoli, V Commissioner Of Income Chandrapur, S Tax, Maharashtra – 442401. Chandrapur Circle, Chandrapur. Pan: Aaafc8556F Appellant / Assessee Respondent / Revenue Assessee By Shri Mukesh Agrawal – Ar Revenue By Shri Abhay Y. Mrathe – Sr.Dr Date Of Hearing 30/11/2023 Date Of Pronouncement 27/12/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am:

Section 143(3)Section 147Section 148Section 50Section 68

ITAT vide its order ITA No.262/NAG/2013 for A.Y.2009-10 allowed the appeal of the assessee vide order 28.12.2015. Thereafter, the Assessing Officer issued notice under section 148 dated 23.03.2016. Assessee filed a letter to treat the original return filed on 27.09.2009 as Return in response to notice under section 148 ... ld.AR submitted that AO had applied his mind and then decided to make addition under section 68 of the Act. Therefore, issuing notice under section 148 of the Act on the same issue of “Sale of Vehicles” is nothing but change of opinion. Therefore, the notice under section 148

Om Sai Stone Limited, Surat vs. Income Tax Officer, Ward - 2(1)(4), Surat

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

ITA 667/SRT/2023[2012-13]Status: DisposedITAT Surat27 Dec 2023AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 147Section 148Section 254(1)

appeal relates to validity of reopening under Section 147 of the Income Tax Act, 1961 (in short, the Act) and issuance of notice under Section 148 of the Act. The ld. AR of the assessee submits that the case of assessee was reopened on the basis of information received from ... recorded, the Assessing Officer was of the view that the income of assessee chargeable to tax has escaped assessment. The Assessing Officer issued notice under Section 148 of the Act on 24/03/2018. The ld. AR of the assessee submits that the reasons recorded itself was not correct. The assessee filed

Om Sai Stone Limited, Surat vs. Income Tax Officer, Ward- 2(1)(4), Surat

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

ITA 666/SRT/2023[2011-12]Status: DisposedITAT Surat27 Dec 2023AY 2011-12

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 147Section 148Section 254(1)

appeal relates to validity of reopening under Section 147 of the Income Tax Act, 1961 (in short, the Act) and issuance of notice under Section 148 of the Act. The ld. AR of the assessee submits that the case of assessee was reopened on the basis of information received from ... recorded, the Assessing Officer was of the view that the income of assessee chargeable to tax has escaped assessment. The Assessing Officer issued notice under Section 148 of the Act on 24/03/2018. The ld. AR of the assessee submits that the reasons recorded itself was not correct. The assessee filed

Chirag Mishrimal Hirani, Surat vs. The Deputy Commissioner of Income Tax, Circle-1(3), Surat

In the result, appeal of assessee is allowed

ITA 582/SRT/2023[2007-08]Status: DisposedITAT Surat26 Dec 2023AY 2007-08

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.582/Srt/2023 (Ay 2007-08) (Hearing In Physical Court) Chirag Mishrimal Hirani Deputy Commissioner Of 301, Divyadarshan Income-Tax, Circle-1(3), Vs Apartments, B/H Umra Police Surat, Aayakar Bhavan, Station, Surat-395001 Majura Gate, Surat-395001 Pan : Amups 4678 Q अपीलाथ"/Appellant ""यथ" /Respondent

Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 254(1)

aggregated purchases from nine parties. The case of assessee was again reopened under section 147 of the Act and notice under section 148 issued on 29.03.2014 was served upon the assessee. The case of assessee was re-opened on the basis of information that M/s Vitrag Jewels is managed ... case of assessee migrated to NFAC. Before NFAC/Ld.CIT(A) the assessee challenged the validity of re-opening under section 147 and issuance of notice under section 148 thereto as well as addition on merit. The assessee also challenged the action of Assessing Officer in not “not serving the time”. Before

DCIT, New Delhi vs. M/S. Suruchi Foods Pvt. Ltd., New Delhi

In the result, the appeal is dismissed

ITA 3536/DEL/2017[2006-07]Status: DisposedITAT Delhi22 Dec 2023AY 2006-07

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

Section 143(1)Section 144Section 147Section 148

Tuticorin Trexim Pvt. Ltd. Based on such information, the Assessing Officer reopened the assessment under Section 147 of the Act and issued a notice under Section 148 of the Act on 25.03.2013 requiring the assessee to file its return of income. As observed by the Assessing Officer, assessee ... passed, assessee preferred an appeal before learned First Appellate Authority, inter alia, on the ground that in absence of valid service of notice under Section 148 of the Act, the assessment order is invalid. CO No.115/Del/2023 5. Having gone through the facts and material on record and being convinced with

Sarita Alice Sequeira, Goa vs. Income Tax Officer, Ward - 11(2)(1), Mumbai

In the result, adjournment request of the assessee is rejected and appeal of the assessee is allowed for statistical purposes

ITA 2913/MUM/2023[2011-12]Status: DisposedITAT Mumbai21 Dec 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Income Tax Officer, Sarita Alice Sequeira Ward-11(2)(1) C/O Manish D. Ladage & Co. Room No.673/674, Chartered Accountants, Aaykar Bhavan, 1003/04, Centrum It Park, Vs. Next To Satkar Grande Hotel, Maharshi Karve Road, Wagle Estate, Thane, New Marine Lines, Mumbai-400 604 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aylps9213Q Assessee By : Shri Ashwin Jain, Ar Revenue By : Shri Prashant Mahajan, Dr Date Of Hearing: 14.12.2023 Date Of Pronouncement : 21.12.2023

For Appellant: Shri Ashwin Jain, ARFor Respondent: Shri Prashant Mahajan, DR
Section 143(1)Section 143(3)Section 147Section 148

assessee the above short term capital gain was not shown and therefore, the case of the assessee was reopened by issue of notice under Section 148 of the Act on 28th March, 2018. The assessee reiterated her return originally filed on 26th April, 2018. 05. The assessee was issued

Vinipul Inorganics Foods Private Limited, Chembur, Mumbai vs. Income Tax Officer Ward 14 (3) (2), Mumbai, Maharshi Karve Road

In the result both the appeals filed by the Assessee are partly allowed

ITA 2510/MUM/2023[2010-2011]Status: DisposedITAT Mumbai21 Dec 2023AY 2010-2011

Bench: Sh.Narendra Kumar Choudhry () & Shri S Rifaur Rahman ()

Section 131Section 143(1)Section 143(3)Section 147Section 148Section 250Section 254Section 69C

Assessee for the assessment year 2010-11 was accordingly reopened under section 147 of the I.T. Act, 1961 by issuing the notice under section 148 with the prior approval of erstwhile Addl.CIT-10(2), Mumbai. Vide order dated 25-03-2014 under section 143(3) read with section