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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

Rajrani Kishanlal Pahwa, Surat vs. ITO, Ward 1(2)(1), Surat

In the result, the appeal of the assessee for AY 2009-10 is partly allowed

ITA 996/SRT/2025[2013-14]Status: HeardITAT Surat22 Jan 2026AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Suresh K. Kabra, CAFor Respondent: Shri Ajay Uke, Sr DR
Section 143(3)Section 147Section 148Section 250

maintaining an undisclosed savings bank account with Sutex Co-operative Bank Ltd., the assessment was reopened u/s 147 of the Act and notice under section 148 was issued on 25.03.2015. In response, the assessee filed a revised return of income on 22.04.2015 declaring total income of Rs.3,58,951/-. During ... Kishanlal Pahwa Vs. ITO Asst. Year : 2009-10 , 2011-12, 2013-14 - 6– 11. In the present case, the assessee, in response to notice under section 148, filed a return declaring income of Rs.38,929/- on a turnover of Rs.4,56,319/-, resulting in a profit rate

Rajrani Kishanlal Pahwa, Surat vs. ITO, Ward 1(2)(1), Surat

In the result, the appeal of the assessee for AY 2009-10 is partly allowed

ITA 995/SRT/2025[2011-12]Status: HeardITAT Surat22 Jan 2026AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Suresh K. Kabra, CAFor Respondent: Shri Ajay Uke, Sr DR
Section 143(3)Section 147Section 148Section 250

maintaining an undisclosed savings bank account with Sutex Co-operative Bank Ltd., the assessment was reopened u/s 147 of the Act and notice under section 148 was issued on 25.03.2015. In response, the assessee filed a revised return of income on 22.04.2015 declaring total income of Rs.3,58,951/-. During ... Kishanlal Pahwa Vs. ITO Asst. Year : 2009-10 , 2011-12, 2013-14 - 6– 11. In the present case, the assessee, in response to notice under section 148, filed a return declaring income of Rs.38,929/- on a turnover of Rs.4,56,319/-, resulting in a profit rate

Rajrani Kishanlal Pahwa, Surat vs. ITO, Ward 1(2)(1), Surat

In the result, the appeal of the assessee for AY 2009-10 is partly allowed

ITA 994/SRT/2025[2009-10]Status: HeardITAT Surat22 Jan 2026AY 2009-10

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Suresh K. Kabra, CAFor Respondent: Shri Ajay Uke, Sr DR
Section 143(3)Section 147Section 148Section 250

maintaining an undisclosed savings bank account with Sutex Co-operative Bank Ltd., the assessment was reopened u/s 147 of the Act and notice under section 148 was issued on 25.03.2015. In response, the assessee filed a revised return of income on 22.04.2015 declaring total income of Rs.3,58,951/-. During ... Kishanlal Pahwa Vs. ITO Asst. Year : 2009-10 , 2011-12, 2013-14 - 6– 11. In the present case, the assessee, in response to notice under section 148, filed a return declaring income of Rs.38,929/- on a turnover of Rs.4,56,319/-, resulting in a profit rate

Yusufbhai Gafurbhai Shaikh, Surat vs. I.T.O Ward- 3(2)(6), Surat

In the result, the appeal of the assessee is allowed

ITA 494/SRT/2025[2010-11]Status: HeardITAT Surat22 Jan 2026AY 2010-11

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 133Section 133(6)Section 147Section 148Section 234Section 250

support of computation and payment of taxes. Despite the above submissions and evidences placed on record, the Assessing Officer proceeded to issue notice under section 148 of the Act and completed the reassessment. The reopening was upheld by the Ld. CIT(A). 4. Aggrieved by the order

Vijay Kumar Jha, Muzaffarpur vs. Ac/DCIT Central Circle, Muzaffarpur

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 415/PAT/2025[2016-17]Status: DisposedITAT Patna22 Jan 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

Section 139(1)Section 142(1)Section 148

condoned for all the appeals. 4. The facts in brief in ITA No. 412/PAT/2025 are that the assessee did not file ITR. Notice under section 148 of the Income Tax Act, 1961 was issued on 14.03.2019 after taking prior approval of ld. Pr. CIT, Muzaffarpur

Vijay Kumar Jha, Muzaffarpur vs. Ac/DCIT Central Circle, Muzaffarpur

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 414/PAT/2025[2015-16]Status: DisposedITAT Patna22 Jan 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

Section 139(1)Section 142(1)Section 148

condoned for all the appeals. 4. The facts in brief in ITA No. 412/PAT/2025 are that the assessee did not file ITR. Notice under section 148 of the Income Tax Act, 1961 was issued on 14.03.2019 after taking prior approval of ld. Pr. CIT, Muzaffarpur

Vijay Kumar Jha, Muzaffarpur vs. Ac/DCIT Central Circle, Muzaffarpur

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 413/PAT/2025[2014-15]Status: DisposedITAT Patna22 Jan 2026AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

Section 139(1)Section 142(1)Section 148

condoned for all the appeals. 4. The facts in brief in ITA No. 412/PAT/2025 are that the assessee did not file ITR. Notice under section 148 of the Income Tax Act, 1961 was issued on 14.03.2019 after taking prior approval of ld. Pr. CIT, Muzaffarpur

Vijay Kumar Jha, Muzaffarpur vs. Ac/DCIT Central Circle, Muzaffarpur

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 412/PAT/2025[2013-14]Status: DisposedITAT Patna22 Jan 2026AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

Section 139(1)Section 142(1)Section 148

condoned for all the appeals. 4. The facts in brief in ITA No. 412/PAT/2025 are that the assessee did not file ITR. Notice under section 148 of the Income Tax Act, 1961 was issued on 14.03.2019 after taking prior approval of ld. Pr. CIT, Muzaffarpur

Vishal Ramesh Fegade, Aurangabad vs. Assessing Officer, Ward 1(5), Aurangabad

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

ITA 2503/PUN/2025[2020-21]Status: DisposedITAT Pune22 Jan 2026AY 2020-21

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2503/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Vishal Ramesh Fegade, Vs. Ito, Ward- 1(5), A-B-8, Tapadia Pride, Aurangabad. Paithan Road, Aurangabad- 431001. Pan : Aanpf6699K Appellant Respondent Assessee By : Shri Anup Shaha Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing : 14.01.2026 Date Of Pronouncement : 22.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 27.08.2025 Which Is Arising Out Of The Assessment Order U/S 147 Of The Act For Assessment Year 2020-21 Framed On 17.03.2013 By The Ito, Ward-1(5), Aurangabad. 2. The Assessee Has Raised Following Grounds Of Appeal :- “1. I, Vishal Ramesh Fegade, Am A Salaried Employee & My Primary Source Of Income Is Derived Solely From My Employment. I Would Like To Explicitly State That I Have Not Made Any Cash Payments In Relation To The Purchase Of The Property In Question. All Payments Made Towards The Acquisition Of The Property Have Been Conducted Through Formal Banking Channels, Ensuring Full Transparency & Compliance With Legal Requirements. The Details Of These Payments Are Clearly Outlined In The Purchase Deed.

For Appellant: Shri Anup ShahaFor Respondent: Shri Shashank Ojha (Virtual)
Section 132Section 143(2)Section 147Section 148Section 151ASection 69

recording of investments in books of account is not satisfied. 3. Learned Jurisdictional Assessing Officer assumed the jurisdiction by issuance of a notice under section 148 of the Income-tax Act, 1961 which was not in accordance with the provisions of section 151A of the Income tax Act, 1961. Further ... CBDT notification the notice under section 148 of the Income tax Act, 1961 ought to have been issued by the National Faceless Assessment Centre (NFAC) and not by the AO. Thus, the notice issued under section 148 of the Income tax Act, 1961 seems to be viod ab initio

Meenakshisundaram Balamurugan, Dindgul vs. CIT(2) 2, Madurai

In the result, all the appeals filed by the assessee are dismissed

ITA 3547/CHNY/2025[2018-19]Status: DisposedITAT Chennai22 Jan 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. Nos.3545, 3546 & 3547/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19 Meenakshisundaram Balamurugan, Vs. The Income Tax Officer, 13-3-2, Chinnapillai Street, Nilakkottai, Ward 1, Nilakottai H.O., Dindigul 624 208. Dindigul. [Pan:Afrpb7358C]

For Appellant: Shri D. Selvamuthukkumaran, FCAFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT
Section 139Section 145(3)Section 147Section 148Section 270A(2)(b)Section 271B

account of ICICI Bank Ltd. and not filed his return of income. The Assessing Officer reopened the case of the assessee and issued notice under section 148 of the Act dated 25.03.2024. The Assessing Officer noted from the income tax return filed by the assessee in response to the notice

Meenakshisundaram Balamurugan, Dindigul vs. CIT(A) 2, Madurai

In the result, all the appeals filed by the assessee are dismissed

ITA 3546/CHNY/2025[2018-19]Status: DisposedITAT Chennai22 Jan 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. Nos.3545, 3546 & 3547/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19 Meenakshisundaram Balamurugan, Vs. The Income Tax Officer, 13-3-2, Chinnapillai Street, Nilakkottai, Ward 1, Nilakottai H.O., Dindigul 624 208. Dindigul. [Pan:Afrpb7358C]

For Appellant: Shri D. Selvamuthukkumaran, FCAFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT
Section 139Section 145(3)Section 147Section 148Section 270A(2)(b)Section 271B

account of ICICI Bank Ltd. and not filed his return of income. The Assessing Officer reopened the case of the assessee and issued notice under section 148 of the Act dated 25.03.2024. The Assessing Officer noted from the income tax return filed by the assessee in response to the notice

Meenakshisundaram Balamurugan, Dindigul vs. CIT(A) 2, Mudurai, Madurai

In the result, all the appeals filed by the assessee are dismissed

ITA 3545/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Jan 2026AY 2017-18

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. Nos.3545, 3546 & 3547/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19 Meenakshisundaram Balamurugan, Vs. The Income Tax Officer, 13-3-2, Chinnapillai Street, Nilakkottai, Ward 1, Nilakottai H.O., Dindigul 624 208. Dindigul. [Pan:Afrpb7358C]

For Appellant: Shri D. Selvamuthukkumaran, FCAFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT
Section 139Section 145(3)Section 147Section 148Section 270A(2)(b)Section 271B

account of ICICI Bank Ltd. and not filed his return of income. The Assessing Officer reopened the case of the assessee and issued notice under section 148 of the Act dated 25.03.2024. The Assessing Officer noted from the income tax return filed by the assessee in response to the notice

Anthonysamy Innasi, Thanjavur vs. ITO, Ward-1, Thanjavur

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

ITA 3276/CHNY/2025[2020-21]Status: DisposedITAT Chennai22 Jan 2026AY 2020-21

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3276/Chny/2025 निर्धारण वर्ष/Assessment Year: 2020-21 Shri Anthonysamy Innasi, The Income Tax Officer, 187, Melaiyur, Nadar Street, Vs. Ward 1(1), Thiruvidaimarudur, Thanjavur Thanjavur – 612 101. (प्रत्यर्थी/Respondent) Pan: Akfpi 0542L (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By : Shri S. Girish Kumar, Advocate प्रत्यर्थी की ओर से/Respondent By : Ms. R. Kavitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 21.01.2026 घोषणा की तारीख/Date Of Pronouncement : 22.01.2026 आदेश/Order Per George George K: This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 22.09.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Year Is 2020-21. :-2 -:

For Appellant: Shri S. Girish Kumar, AdvocateFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

validity of the assumption of jurisdiction for issuance of notice under section 148A of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer, Ward 1(1), Trichy is lacking jurisdiction in view of Notification issued by the CBDT ... clear that the respondents have erred in not following the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022. Since notices under Section 148 of the Act were not issued in a faceless manner, the entire further proceeding founded upon it and assessment orders stand vitiated. Thus, the impugned

Gnanamani Thuraichi, Tenkasi vs. Income Tax Officer, Ward -1, Tirunelveli

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

ITA 3263/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3263/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Smt. Gnanamani Thuraichi, The Income Tax Officer, 7-3-3(8), Palace Street, Vs. Ward 1, Anaikulam, Tirunelveli Kamarajar Nagar, Tenkasi – 627 859. Pan: Bdmpg 5319J (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri K. Vishwa Padmanaban, Ca ""यथ" क" ओर से/Respondent By : Ms. R. Kavitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 21.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 22.01.2026

For Appellant: Shri K. Vishwa Padmanaban, CAFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

outset, we notice that the assessee has filed additional grounds of appeal challenging the validity of the assumption of jurisdiction for issuance of notice under section 148 of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer, Ward ... material on record. By way of Additional grounds of appeal, the assessee has raised legal issue of assumption of jurisdiction for issuance of notice under section 148 of the Act. Since the additional ground raised by the assessee relate to a pure legal issue, which does require examination

Anbazhagan Elango, Kanchipuram vs. ITO, Ward-1, Kancheepuram

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

ITA 3249/CHNY/2025[2018-19]Status: DisposedITAT Chennai22 Jan 2026AY 2018-19

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3249/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

validity of the assumption of jurisdiction for issuance of notice under section 148A of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer, Ward 1, Kancheepuram is lacking jurisdiction in view of Notification issued by the CBDT dated ... clear that the respondents have erred in not following the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022. Since notices under Section 148 of the Act were not issued in a faceless manner, the entire further proceeding founded upon it and assessment orders stand vitiated. Thus, the impugned

Jj709 Eguvarpalayam Paccs, Thiruvallur vs. ITO, Ward-1., Thiruvallur

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

ITA 3216/CHNY/2025[2018-19]Status: DisposedITAT Chennai22 Jan 2026AY 2018-19

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3216/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19

For Appellant: Shri B. Suresh, CAFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

validity of the assumption of jurisdiction for issuance of notice under section 148A of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer, Ward 1, Tiruvallur is lacking jurisdiction in view of Notification issued by the CBDT dated ... clear that the respondents have erred in not following the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022. Since notices under Section 148 of the Act were not issued in a faceless manner, the entire further proceeding founded upon it and assessment orders stand vitiated. Thus, the impugned

G770 Mettupalayam Paccs Ltd., Chennai vs. ITO, Ncw-8(2), Chennai

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

ITA 3215/CHNY/2025[2019-20]Status: DisposedITAT Chennai22 Jan 2026AY 2019-20

Bench: Shri George George Kand Ms Padmavathy S

For Appellant: Shri B. Suresh, CAFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

validity of the assumption of jurisdiction for issuance of notice under section 148A of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer, Non-Corporate Ward 8(2), Chennai is lacking jurisdiction in view of Notification issued ... clear that the respondents have erred in not following the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022. Since notices under Section 148 of the Act were not issued in a faceless manner, the entire further proceeding founded upon it and assessment orders stand vitiated. Thus, the impugned

Jayaraman Srinivasan, Chengalpet vs. ITO, Ncw-22(4), Tambaram

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

ITA 3203/CHNY/2025[2016-17]Status: DisposedITAT Chennai22 Jan 2026AY 2016-17

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3203/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

validity of the assumption of jurisdiction for issuance of notice under section 148A of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer, Non-Corporate Ward 22(4), Tambaram is lacking jurisdiction in view of Notification issued ... clear that the respondents have erred in not following the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022. Since notices under Section 148 of the Act were not issued in a faceless manner, the entire further proceeding founded upon it and assessment orders stand vitiated. Thus, the impugned

S 1284 Thathaiyangarpatti Paccs Ltd., Namakkal vs. ITO, Ward-2, Namakkal

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

ITA 3173/CHNY/2025[2019-20]Status: DisposedITAT Chennai22 Jan 2026AY 2019-20

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3173/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20

For Appellant: Shri A. Tamilamudan, CAFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

validity of the assumption of jurisdiction for issuance of notice under section 148A of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer, Ward 2, Namakkal is lacking jurisdiction in view of Notification issued by the CBDT dated ... clear that the respondents have erred in not following the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022. Since notices under Section 148 of the Act were not issued in a faceless manner, the entire further proceeding founded upon it and assessment orders stand vitiated. Thus, the impugned

Gunasekaran Mannar, Villupuram vs. Asst. Commissioner of Income Tax, Chennai

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

ITA 1864/CHNY/2025[2018-19]Status: DisposedITAT Chennai22 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 115BSection 132Section 139(1)Section 147Section 148

modified/suppressed sales" as suppressed cash sales. The AO treated the case as one falling under Explanation 2 to Section 148 and issued a notice under Section 148 of the Act dated 30.03.2023 for AY 2017-18. In response to the said notice issued under section 148, the assessee filed