“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

DCIT-10(2)(1), Mumbai vs. M/S.Jyothy Laboratories Limited, Mumbai

In the result, both the appeals of the revenue are dismissed and Cross Objection filed by the assessee are partly allowed

ITA 3875/MUM/2018[2013-14]Status: DisposedITAT Mumbai28 Dec 2022AY 2013-14

Bench: Shri Amit Shukla & Shri Amarjit Singh

For Appellant: Solgy Jose T. KottaramFor Respondent: J.D. Mistry

Section 115JSection 143(2)Section 143(3)Section 14ASection 229Section 80I

been raised is that when the assessment for the instant year was finalised under Section 143(3) of the Act dated 31.03.2014, a notice under Section 148 of the Act was issued on 21.03.2014 to reopen the assessment for Assessment Year 2009-10 in order to withdraw the claim earlier ... initial assessment year was disturbed. On this aspect, the learned representative for the respondent assessee vehemently pointed out that issuance of a notice under Section 148 of the Act to reopen assessment to withdraw a claim would not mean ‘withdrawal of claim ipso facto’. It was emphasised that

M/S. Glint Infraprojects Pvt. Ltd, Mumbai vs. Pr. Comm of Income Tax Officer, Mumbai-1

In the result, the appeal filed

ITA 871/MUM/2022[2012-13]Status: DisposedITAT Mumbai27 Dec 2022AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13 M/S Glint Infraprojects Pvt. Pr. Cit-1, Ltd, Room No. 330, 3Rd Floor, 5Th Floor, Sunteck Centre, 37- Vs. Aayakar Bhavan, Maharshi 40, Subhash Road, Vile Parle Karve Road, (East), Mumbai-400020. Mumbai-400057. Pan No. Aadcg 5620 L Appellant Respondent Assessee By : Mr. Rakesh Joshi Revenue By : Mr. Ashok Kumar Kardam, Cit-Dr : Date Of Hearing 02/11/2022 Date Of Pronouncement : 27/12/2022

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Ashok Kumar Kardam, CIT-DR

Section 143(3)Section 147Section 263

rationale, the assessment was reopened under section economic rationale, the assessment was reopened under section 147 of the Act by way of issuing notice under section 148 of the by way of issuing notice under section 148 of the by way of issuing notice under section 148 ... 30/03/2019. In response to the notice under section 148 of the on 30/03/2019. In response to the notice under section 148 of the on 30/03/2019. In response to the notice under section 148 of the Act, the assessee filed return of income on 19/04/2019 reiterating , the assessee filed return

ACIT -1(1)(1), Mumbai vs. M/S Adhiraj Construction Private Limited, Mumbai

In the result, the appeal of the revenue and the cross objection filed by the assessee are dismissed

ITA 1410/MUM/2022[2012-2013]Status: DisposedITAT Mumbai27 Dec 2022AY 2012-2013

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

Total Rs. 7,20,00,000/- Hence, the Assessing Officer reopened the assessment of the year under consideration by issuing notice under section 148 of the Act dated 8.12.2016. Copy of the reasons recorded for reopening the assessment was furnished to the assessee. In response thereto, the assessee vide letter

Hitesh Jitendra Parikh, Mumbai vs. Income Tax Officer-5(1)(1), Mumbai

ITA 2370/MUM/2022[2010-2011]Status: DisposedITAT Mumbai23 Dec 2022AY 2010-2011

Bench: Shri Kuldip Singhassessment Year: 2010-11

For Appellant: Shri Biren Gabhawala, A.RFor Respondent: Shri Krishna Kumar, D.R

Section 143(1)Section 143(3)Section 147Section 148Section 149(1)Section 271(1)

again processed under section 143(1) vide 4 M/s. Hitesh Jitendra Parikh order dated 28.03.2012. It is also not in dispute that notice under section 148 of the Act dated 23.03.2016 was served upon the assessee on 31.03.2016. It is also not in dispute that the assessee has raised objection ... record facts as to the Long Term/Short Term Capital Gain qua the property 7 M/s. Hitesh Jitendra Parikh in question but issuing notice under section 148 of the Act on 23.03.2016 served on the assessee on 31.03.2016 being beyond the period of four years is not a valid notice

Jivanji Metal Wares Private Limited, Mumbai vs. Income Tax Officer-6(3)(3), Mumbai

The appeal is partly allowed

ITA 2229/MUM/2022[2009-2010]Status: DisposedITAT Mumbai23 Dec 2022AY 2009-2010

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajgopal, Jm Jivanji Metal Wares Pvt. Ltd. Ito-6(3)(3) 67, Dada Mansion, 3 Rd Floor, Aayakar Bhavan, M.K.Road, Mohammedali Road, Vs. Mumbai - 400 020 Mumbai- 400 003 (Appellant) (Respondent) Pan No. Aabcj5775D Assessee By : None Revenue By : Shri. Ajay Kumar Kesari Sr Ar Date Of Hearing: 25.10.2022 Date Of Pronouncement : 23.12.2022

For Appellant: NoneFor Respondent: Shri. Ajay Kumar Kesari SR AR

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 253Section 69C

Subsequently, the assessment of the Jivanji Metal Wares Pvt. Ltd.; A.Y. 2009-10 assessee was reopened by issuing notice under Section 148 of the Act on 13th March, 2014 recording the reasons that based on enquires conducted by Sales Tax Department of Maharashtra, assessee has taken accommodation entries from five

M/S Realtime Properties Ltd., Mumbai vs. DCIT, Central Circle-5(3), Mumbai

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

ITA 925/MUM/2020[2011-12]Status: DisposedITAT Mumbai23 Dec 2022AY 2011-12

Bench: Shri Amarjit Singh & Ms. Kavitha Rajagopals (A.Y.2011-12)

For Appellant: NoneFor Respondent: Anil Sant

Section 115JSection 143(1)Section 143(2)Section 144Section 147Section 148Section 151

sanction as required under section 151 of the Act has not been obtained from the Commissioner of Income Tax before issue of notice under section 148 of the Act or having been obtained the copy of the same has not been provided to the Appellant, which is against the principles

General Electric Company, Mumbai vs. Asst DIT (It) 3(1), Mumbai

In the result, the appeal of the assessee for Assessment Year 2001-02 is allowed and the appeal of revenue for A

ITA 82/MUM/2011[2001-02]Status: DisposedITAT Mumbai23 Dec 2022AY 2001-02

Bench: Shri Aby T Varkey & Shri M Balaganeshm/S. General Electric Company, C/O Kpmg, Lodha Excelus, Apollo Mills Compound, N.M. Joshi Marg, Mahalaxmi, Mumbai-400011 Pan Aaacg5399M …Appellant. Vs. Asst. Director Of Income Tax, (International Taxation)-3(1), Room No.136, 1St Floor, Scindia House, N M Road Ballard Estate, Mumbai-400038. ….Respondent. Dy. Commissioner Of Income Tax, International Taxation-3(1), Mumbai-400 038 ….Appellant. Vs. M/S. General Electric Company, Mahalaxmi, Mumbai. ….Respondent. Assessee By : Shri Percy Pardiwala, Ms. Fereshte Sethna, Shri Mrunal Parekh, Shri Abhishek Tilak & Shri Ameya Pany. Revenue By : Ms. Surabi Sharma, Cit D.R. Shri Sunil Umap, Cit- D.R. Date Of Hearing : 15.12.2022 Date Of Pronouncement : 23.12.2022

For Appellant: Shri Percy PardiwalaFor Respondent: Ms. Surabi Sharma, CIT

Section 139Section 143Section 143(3)Section 147Section 148Section 5Section 9

turn filed in compliance to the said notice. The assessee also made detailed submissions objecting to the reopening. We find that notice under section 148 of the Act was issued on the assessee on 31.3.2008. The assessee filed a reply on 29.5.2008 in response to the notice under section 148 ... stating that the return already filed may be treated as a return filed in response to notice under section 148 of the Act. In the said letter, the assessee had duly sought for reasons recorded by the learned Assessing Officer for reopening the assessment. This letter is enclosed in pages

DDIT (It) 3(1), Mumbai vs. General Electric Company, Mumbai

In the result, the appeal of the assessee for Assessment Year 2001-02 is allowed and the appeal of revenue for A

ITA 432/MUM/2011[2001-02]Status: DisposedITAT Mumbai23 Dec 2022AY 2001-02

For Appellant: Shri Percy PardiwalaFor Respondent: Ms. Surabi Sharma, CIT

Section 139Section 143Section 143(3)Section 147Section 148Section 5Section 9

Manohar Manak Alloys P.Ltd, Mumbai vs. ACIT 4(2), Mumbai

Appeal is allowed

ITA 1159/MUM/2022[2017-18]Status: DisposedITAT Mumbai22 Dec 2022AY 2017-18

For Appellant: Shri Rajkumar SinghFor Respondent: Shri A.B. Koli

Section 143(1)Section 143(3)Section 147Section 263Section 263(1)

income which had escaped assessment other than or in addition to that item or items which have led to the issuance of notice under section 148 and where reassessment is made under section 147 in respect of income which has escaped tax, the Income-tax Officer's jurisdiction is confined ... issue which comes to the notice in the course of the proceedings under the section, though the reasons which were recorded in the notice under section 148(2) did not contain reference to that issue. 10. The submission which has been urged on behalf of the revenue is that when

M/S K.M. Khadim & Co., Kolkata vs. PCIT-1, Kolkata

In the result, the appeal of the assessee is allowed

ITA 278/KOL/2022[2014-15]Status: DisposedITAT Kolkata21 Dec 2022AY 2014-15

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 263

assess or reassess the income in respect of any issue, even an issue in respect of which no reasons were indicated in the notice under section 148(2). This, however, will not obviate the bar of limitation under section 263(2). The invocation of the jurisdiction under section

Pine Tree Consultants P.Ltd., Mumbai vs. Dy CIT Circle - 3(2)(2), Mumbai

In the result, the three appeals filed by the assessee are allowed

ITA 1695/MUM/2020[2014-15]Status: DisposedITAT Mumbai21 Dec 2022AY 2014-15

Bench: Shri Baskaran Br & Shri Pavan Kumar Gadaleita No.1696/Mum/2020 (A.Y: 2013-14) Pine Tree Consultants Vs. Dcit, Circle – 3(2)(2) Pvt Ltd, No.104, Raheja Aayakar Bhavan, Centre, 1St Floor, Mk Road, Free Press Journal Mumbai -400020. Marg, Nariman Point, Mumbai -400 021 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcp8816F Appellant .. Respondent Appellant By : Mr.Neelkanth Khandelwal.Ar Respondent By : Ms.Deepika Arora.Dr Date Of Hearing 23.11.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: These Are The Three Appeals Filed By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax(Cit(A))-8 Mumbai Passed Under Sec250 Of The Act

For Appellant: Mr.Neelkanth Khandelwal.ARFor Respondent: Ms.Deepika Arora.DR

Section 133(6)Section 143(2)Section 148Section 68

upholding the action of the Deputy Commissioner of Income-tax 3(2)(2), 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 issue

ITO -8(2)(4), Mumbai vs. Symmetree Realty Ventures Pvt. Ltd., Mumbai

ITA 4005/MUM/2017[2009-10]Status: DisposedITAT Mumbai20 Dec 2022AY 2009-10

Bench: Shri Kuldip Singh & Shri Gagan Goyal

For Appellant: NoneFor Respondent: Shri Rakesh Garg, D.R

Section 143(3)Section 148

invalid and illegal being formed on the basis of assumptions and incorrect facts and observations and sought to quash the notice under section 148 of the Act. ITA Nos.4004 & 4005/M/2017 & 11 CO Nos.289 & 290/M/2018 M/s. Symmetree Realty Ventures Pvt. Ltd. 16. The Ld. CIT(A) after examining the facts rejected

ITO-8(2)(4), Mumbai vs. Symmetree Realty Ventures Pvt. Ltd., Mumbai

ITA 4004/MUM/2017[2008-09]Status: DisposedITAT Mumbai20 Dec 2022AY 2008-09

Bench: Shri Kuldip Singh & Shri Gagan Goyal

For Appellant: NoneFor Respondent: Shri Rakesh Garg, D.R

Section 143(3)Section 148

Vulvan Traders Private Limited, Mumbai vs. Principle Commissioner of Income Tex, Mumbai-5, Mumbai

The appeal of the assessee is allowed

ITA 1318/MUM/2022[2012-2013]Status: DisposedITAT Mumbai19 Dec 2022AY 2012-2013

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Principle Commissioner Of Vulvan Traders Private Income Tax, Limited 515, 5Th Floor, 805A, Corporate Avenue, Aaykar Bhavan, Sonawala Road, Vs. Goregaon (East) Mk Road, Mumbai-400 063 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaacv1603K Assessee By : Shri Rajeev Khandelwal, Ar Revenue By : Shri Achal Sharma, Cit Dr Date Of Hearing: 21.09.2022 Date Of Pronouncement : 19.12.2022

For Appellant: Shri Rajeev Khandelwal, ARFor Respondent: Shri Achal Sharma, CIT DR

Section 143(3)Section 147Section 148Section 263

appellate 4th effect order dated September, 2018 at ₹2,73,520/-. 05. Subsequently, the case of the assessee was reopened by issuing notice under Section 148 of the Act dated 28March 2019. As per the reasons recorded information was received from DDIT, Investigation Wing, Mumbai on 22nd March, 2019 that ... claim that the sale amount corresponding to the outstanding debtor was offered to tax in earlier years. In response to the above notice under Section 148 of the Act, assessee filed its return of income on 30th May, 2019 at ₹2,73,518/-. Assessee requested for the reasons of reopening

Mrunal Nilesh Desai, Thane vs. ACIT, Circle 19(2), Mumbai

In the result, appeal filed by the assessee is party allowed with above direction

ITA 1462/MUM/2022[2010-11]Status: DisposedITAT Mumbai15 Dec 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am Mrunal Nilesh Desai Acit,Circle 19(2) 12/D, Cedar Co-Op Housing 2Nd Floor, Matru Mandir Society, Edenwoods Cross Bldg, Tardeo, Grant Road, Vs. Pokhram 2, Mumbai-400 007 Thane (W) - 400 610 (Respondent) (Appellant) Pan No. Afepd5715N Assessee By : Shri. Tanmay Phadke Revenue By : Shri. Ujjawal Chavan Sr Ar Date Of Hearing: 19.09.2022 Date Of Pronouncement : 15/12/2022

For Appellant: Shri. Tanmay PhadkeFor Respondent: Shri. Ujjawal Chavan SR AR

Section 144Section 147Section 148

available that assessee has transferred of property of ₹15 lacs on 14th January 2010 and no capital gain is declared, therefore, the notice under Section 148 of the Act was issued on 30th March, 2017 which remained uncomplied with. The show cause notice was issued on 12th December, 2017, nobody

Arvind Mohanlal Jain, Mumbai vs. CIT (A)-3, Thane

In the result, we quash the reassessment initiation

ITA 1798/MUM/2020[2008-09]Status: DisposedITAT Mumbai15 Dec 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am Arvind Mohanlal Jain Cit(A)-3 Flat No.304, Room No-30, D-Wing, Vishwanath Nagar, B-Wing, Asher It Park, Vs. Gandhi Chowk, Wagle Industrial Estate, Kulgaon, Badlapur (E) Thane 400 604 Mumbai-421 503 (Appellant) (Respondent) Pan No. Aarpj2456J

For Appellant: Shri Piyush Chhajed, ARFor Respondent: Shri Ujjawal Chavan, SR AR

Section 139(1)Section 143(2)Section 143(3)Section 148Section 234ASection 271(1)(c)

25th March, 2015, regarding cash deposit of ₹30 lacs in his account and immediately same was advanced to one Shri Chandrakant Dedhia. Therefore, notice under Section 148 of the Income- tax Act, 1961 (the Act) was issued on 27th March, 2015. Necessary notices were issued in response to which assessee ... held that where the Joint Commissioner recorded the satisfaction in a mechanical manner and without application of mind to accord sanction to issue notice under Section 148 of the Act of reopening of assessment is invalid. He further referred to the decision of the Hon'ble Bombay High Court

M/S. Ramniklal Sivji Savla, Mumbai vs. CIT (A)-30, Mumbai

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

ITA 1261/MUM/2020[2009-10]Status: DisposedITAT Mumbai15 Dec 2022AY 2009-10

Section 143(1)Section 148

view that the above said purchases as non-genuine in nature. Accordingly he reopened the assessment by issuing 2 M/s. Ramniklal Sivaji Savla notice under section 148 of the Act. The Assessing Officer estimated the income @ 25% of the non-genuine purchases and accordingly made addition

M/S. About U Fashions Private Limited, Mumbai vs. DCIT-15(1)(1), Mumbai

In the result, appeal filed by the assessee for A

ITA 2150/MUM/2018[2011-12]Status: DisposedITAT Mumbai15 Dec 2022AY 2011-12

Section 143(1)Section 148Section 14ASection 68

processed under section 143(1) of the Act. Subsequently, the assessment was reopened by the Assessing Officer by issuing notice under section 148 of the Act for the reason that the assessee has availed loan of Rs. 25 lakhs from a company named M/s. Ansh Merchandise Pvt. Ltd., which happened

Mangayarkarasi Subramaniam, Erode vs. ITO, NFAC, Delhi

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

ITA 850/CHNY/2022[2013-2014]Status: DisposedITAT Chennai14 Dec 2022AY 2013-2014

Bench: Shri V. Durga Raoआयकर अपील सं./I.T.A. No.850/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 Smt. Mangayarkarasi Subramaniam, Vs. The Income Tax Officer, 53/1, Avvaiyar Street, National Faceless Assessment Centre, Erode. 638 011. Delhi. [Pan:Arhpm8094N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 07.12.2022 घोषणा की तारीख /Date Of Pronouncement : 14.12.2022 आदेश /O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 08.09.2022 Relevant To The Assessment Year 2013-14. 2. Brief Facts Of The Case Are That As Per Ast/Air Information On Itd Query, The Assessee Has Deposited Cash Amounting To ₹.13,90,000/- In Her Saving Bank Account During The Financial Year 2012-13 Relevant To The Assessment Year 2013-14. Since The Assessee Has Not Filed Return Of Income, The Assessing Officer Initiated

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

Section 142(1)Section 147Section 148

income, the Assessing Officer initiated 2 I.T.A. No. 850/Chny/22 proceedings under section 147 of the Income Tax Act, 1961 [“Act” in short] and notice under section 148 of the Act dated 18.09.2019 was issued to the assessee requiring her to file the return of income. Since the assessee

Mohamed Hussain Mahamed Harisai, Chennai vs. ITO, Ncw-5(5), Chennai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 655/CHNY/2019[2011-12]Status: DisposedITAT Chennai14 Dec 2022AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./ I.T.A. Nos.654 & 655/Chny/2019 िनधा"रण वष"/Assessment Years: 2010-11 & 2011-12 Shri Mohamed Hussain Mohamed Vs. The Income Tax Officer, Harissi, 10, Nethaji Nagar, Iind Street Non Corporate Ward 5(5), Tondiarpet, Chennai 600 081. Chennai 600 006. [Pan:Apepm2204H] (Petitioner By) (""थ"/Respondent) अपीलाथ" की ओर से / Petitioner By : Shri N. Arjunraj, Ca For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 30.11.2022 घोषणा की तारीख /Date Of Pronouncement : 14.12.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 10, Chennai Both Dated 01.03.2018 Relevant To The Assessment Years 2010- 11 & 2011-12. 2. Both The Appeals Filed By The Assessee Are Time Barred By 277 Days Delay In Filing The Appeals Before The Tribunal. By Filing Condonation Petition In Support Of An Affidavit, The Assessee Has Explained As Under:

For Respondent: Shri AR V Sreenivasan, Addl. CIT

Section 131Section 142(1)Section 144Section 148Section 250(6)Section 69A

made in SB account with M/s. ICICI Bank Ltd. during 3 I.T.A. Nos.654 & 655/Chny/19 the financial year 2009-10 as per AIR information. Notice under section 148 of the Income Tax Act, 1961 [“Act” in short] was issued on the assessee on 31.07.2014. Notice under section