“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

Vikas Chandra HUF, Aligarh vs. ITO Ward-4(1)(1), Aligarh

In the result, the appeal of the assessee is allowed

ITA 450/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshvikas Chandra Huf, Vs. Cit(Appeals), D-117, Ramesh Vihar, Nfac, Delhi Ramghar Road, Aligarh Up (Appellant) (Respondent) Pan: Aakjv9476N Assessee By : Shri Pankaj Garg, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Pankaj Garg, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 139(1)Section 147Section 148Section 148ASection 151

sanction is liable to be declared as nullity and invalid, and resultantly, the impugned order passed under section 148A(d) and the impugned notice under section 148 issued consequent to the grant of sanction are liable to be quashed. 9. Per contra, learned counsel for the respondent while defending ... case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under section 148, need not issue such notice himself." 12. A plain reading of the aforesaid provision clearly indicates that the prescribed authority must be "satisfied

Narayani Rathore, Shivpuri vs. Assessment Unit, Income Tax Department, Delhi

In the result, appeal filed by the assessee is allowed

ITA 444/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshnarayani Rathore, Vs. Assessment Unit, Peeroth Shivpuri, Income Tax Shivpuri, Mp Department, National Faceless Appeal Centre, Delhi (Appellant) (Respondent) Pan: Dhgpr1886H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 151A

make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment or recomputation under section 147 or issuance of notice under section 148 [or conducting of enquiries or issuance of show-cause notice or passing of order under section 148A] or sanction for issue of such ... notify the Scheme for : (i) the purpose of assessment, reassessment or recomputation under Section 147; or Gauri Gaekwad 63/87 904.WP-1778-2023.doc (ii) issuance of notice under Section 148; or (iii) conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or (iv) sanction for issuance

Sunita, Sahu vs. Assessment Unit, Income Tax Department, Delhi

In the result, appeal filed by the assessee is allowed

ITA 432/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 151A

make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment or recomputation under section 147 or issuance of notice under section 148 [or conducting of ITA No. 432/AGR/2025 enquiries or issuance of show-cause notice or passing of order under section 148A] or sanction ... notify the Scheme for : (i) the purpose of assessment, reassessment or recomputation under Section 147; or Gauri Gaekwad 63/87 904.WP-1778-2023.doc (ii) issuance of notice under Section 148; or ITA No. 432/AGR/2025 (iii) conducting of inquiry or issuance of show cause notice or passing of order under Section 148A

Mahavir Agro Industries, Na vs. Arivs.ITO, Ward-3, Navsari

In the result, the appeal of the assessee is partly allowed

ITA 1011/SRT/2024[2012-13]Status: HeardITAT Surat21 Jan 2026AY 2012-13

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

For Appellant: Shri Rajesh Upadhyay, A.RFor Respondent: Ms. Namita Patel Sr. D.R

Section 148

information and also that of the statement alongwith other material the Assessing Officer with proper approvals and after recording the reasons, has issued notice under Section 148 of the Act. There is no procedural or legal lapse on part of the Assessing Officer while issuing the notice under Section 148

Misrilall Jain & Sons, Singhbhum West vs. ACIT, Central Circle-1, Ranchi

In the result the appeal filed by the assessee is allowed

ITA 468/RAN/2024[2017-18]Status: DisposedITAT Ranchi21 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.468/Ran/2024 Assessment Year: 2017-18 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 30.07.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(3)Section 148Section 148ASection 250

assessee submitted that the alleged escaped income of ₹1,32,63,010 had already been disclosed in the return filed in response to notice under section 148 of the act and, therefore, there was no further escapement of income. The Assessing Officer rejected the assessee’s explanation and passed ... order under section 148A(d) holding it to be a fit case for reopening. Consequently, another notice under section 148 dated 21.07.2022 was issued. In response, the assessee again filed its return declaring total income of ₹1,32,63,010, which was accepted as returned income. However, while completing

Binod Choudhary, Ramgarh, Jharkhand vs. Inocme Tax Officef, Ramgarh

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

ITA 443/RAN/2024[2015-16]Status: DisposedITAT Ranchi21 Jan 2026AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.443/Ran/2024 Assessment Year: 2015-16 Binod Choudhary……………………..…….…............................……….……Appellant Maa Santana Complex, Thana Chowk, Ramgarh, Jharkhand- 828122. [Pan: Axdpc5704B] Vs. Ito, Ward-2(3), Ramgarh…...….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 16, 2026 Date Of Pronouncing The Order : January 21, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 24.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is An Individual & A Non-Filer Of Income-Tax Return. In The Case Of The Assessee, Information Was Received From The Annual Information Report (Air)/Al, On The Basis Of Which The Assessing Officer Initiated Proceedings Under The Income- Tax Act. Accordingly, Notice Under Section 148 Of The Act, Followed By Proceedings Under Section 148A(B), Was Issued To The Assessee. It Was The Contention Of The Assessee That Since The Taxable Income Was Below The Prescribed Threshold, No Return Of Income Was Filed For Assessment Year 2015–16. However, It Was Noticed By The Assessing Officer That The

Section 148Section 148ASection 250

from the Annual Information Report (AIR)/AL, on the basis of which the Assessing Officer initiated proceedings under the Income- tax Act. Accordingly, notice under section 148 of the Act, followed by proceedings under section 148A(b), was issued to the assessee. It was the contention of the assessee that

Jitendra Kumar Ray, Lalganj, Hajipur vs. ITO Ward 1(3) Vaishali, Hajipur

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

ITA 344/PAT/2025[2015-16]Status: DisposedITAT Patna21 Jan 2026AY 2015-16

Bench: or at the time of hearing of the Appeal. At the outset of hearing, we noted that the appeal filed by the assessee is delay by 256 days. In this regard, the assessee filed an affidavit dated 14.01.2026 stating the reasons for not filing appeal within the due date which is as under: “We enclose herewith an appeal u/s 253 of the I.T. Act 1961 against the order under section 250 of the Income Tax Act, 1961, relating to

For Respondent: Sh. Manab Adak, JCIT

Section 142(1)Section 143(2)Section 147Section 148Section 234ASection 250Section 253Section 274Section 69

bank account and no return of income was filed, therefore, the case was reopened after completing entire procedures for reopening u/s147 and notice under Section 148 of the Act was issued to the assessee on 30.03.2021 to file return of income. In response to notice under Section 148

Sandhya Singh, Rohit Nagar, Bhopal vs. ITO 2(3) Bhopal, Aaykar Bhawan, Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 584/IND/2025[2013-2014]Status: DisposedITAT Indore21 Jan 2026AY 2013-2014

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Adv. Sh. Gagan TiwariFor Respondent: Date of Hearing

Section 115BSection 143(1)Section 147Section 148Section 69A

Varusha Buildcon, which were not reflected in the return of income. 4. During the reassessment proceedings, the Assessing Officer issued several statutory notices under sections 148 and 142(1) of the Act calling upon the assessee to file the return in response to the notice under section 148, explain

Oneel Verma, Nashik vs. ITO-5(1), Bhopal

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

ITA 394/IND/2025[2009-10]Status: DisposedITAT Indore21 Jan 2026AY 2009-10

Bench: Shri Siddhartha Nautiyal (Judicial Member), Shri B.M. Biyani (Accountant Member)

For Appellant: Shri Devendra Jain, AdvFor Respondent: Shri Ashish Porwal, Sr. D.R

Section 142(1)Section 143(2)Section 144Section 147Section 148Section 250

Faceless Appeal Centre (NFAC) CIT(A) has erred in upholding the action of Ld. Assessing Officer in initiating reassessment proceedings by issuing of notice under section 148 and passing the Assessment Order under section 144 without any valid jurisdiction. 2. In the facts and circumstances of the case ... National Faceless Appeal Centre (NFAC) CIT(A) has erred in upholding the action of Ld. Assessing Officer in completing assessment without serving mandatory notice under section 148. 3. In the facts and circumstances of the case and in law, the Learned National Faceless Appeal Centre (NFAC) CIT(A) has erred

Vimal Alloys Private Limited, Mandi Gobindgarh, Punjab vs. Jao the Deputy Commissioner of Income Tax Circle, Patiala, Punjab

ITA 890/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh21 Jan 2026AY 2016-2017

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 143(1)Section 147Section 148Section 151Section 69A

year under consideration was originally processed under section 143(1) of the Act. Subsequently, the assessment was reopened by issuance of notice under section 148 of the Act. The reopening was based on information received from the Investigation Wing in consequence to a search conducted on World Window Group, including ... debts, in case of banks (Reassessment) - Assessment years 2006-07 and 2007-08 - High Court by impugned order held that where notice under section 148 is to be issued after expiry of four years or before expiry of six years, assessee should have failed to disclose material facts, hence, where

Biru Sharma, Safidon, Jind vs. Income Tax Officer, Ward-1, Jind

In the result, appeal of the assessee is allowed

ITA 1378/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh21 Jan 2026AY 2018-19

Bench: Shri Rajpal Yadavआयकर अपील सं./ Ita No. 1378/Chd/2025 "नधा"रण वष" / Assessment Year. : 2018-19 Shri Biru Sharma, Vs The Ito, S/O Shri Bal Kishan, Ward-1, Purani Mandi, Jind. Safidon, Jind. "थायी लेखा सं./Pan No: Chxps1434E अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashok Kumar Goyal, Ca. Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr Date Of Hearing : 21.01.2026 Date Of Pronouncement : 21.01.2026 O R D E R Physical Hearing Per Raj Pal Yadav, Vp

For Appellant: Shri Ashok Kumar Goyal, CAFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR

Section 148Section 148A(1)

finding of the Tribunal reads as under: “6. We have duly considered the rival contentions and gone through the record carefully. Admittedly, notice under Section 148 was issued after the Notification issued by the Ministry of Finance, Government of India on 29.03.2022. The notice under Section 148 has been issued

Madhav Pandurang Bhanage, Nashik vs. Income Tax Officer, Ward 1(1), Nashik

In the result appeal of the assessee is allowed as per terms indicated herein above

ITA 2553/PUN/2025[2017-18]Status: DisposedITAT Pune21 Jan 2026AY 2017-18

Bench: Dr. Manish Boradआयकर अपील सं./Ita No.2553/Pun/2025 धििाारण वर्ा / Assessment Year: 2017-18 Madhav Pandurang Vs Ito, Ward - Bhanage, 1(1), Nashik Mangalmurti Swami Co-Op Society, Lamkhede Mala, Meri Colony S.O., Nashik- 422004 Maharashtra Pan-Ablpb0449A Appellant Respondent

For Appellant: Shri Chinmay PathakFor Respondent: Shri Vishwajit Shinde

Section 143(3)Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 50C

passed after taking approval from Principal Commissioner of Income Tax (Respondent No.2). Since the aforesaid order was passed, as well as the notice under section 148 was issued, after the expiry of three years from the end of A.Y. 2017-18, as per the substituted provisions of re-assessment ... present case A.Y. 2017-18) expired on 30.06.2021, whereas Respondent No. 1, despite passing order under section 148Ajd) on 18.08.2022, and issuing notice under section 148 on 23.08.2022 respect of Assessment Year 2017-18), has obtained approval of Respondent No.2 who is not the authority as prescribed under section

Spr Publications Private Limited, Hyderabad vs. ITO Ward-3(1), Hyderabad

ITA 2296/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 148ASection 250Section 272A(1)(d)Section 273B

order under section 148A(d) of the Act, dated 28/04/2022, was passed by the ACIT, Circle-3(1), Hyderabad, i.e., JAO. Also, notice under section 148 of the Act, dated 28/04/2022, was issued by the ACIT, Circle-3(1), Hyderabad. However, the assessee company failed to comply with the notice

Bilwa Infrastructure Limited, Hyderabad vs. ITO., Ward-1(1), Hyderabad

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 1363/HYD/2025[2019-20]Status: DisposedITAT Hyderabad21 Jan 2026AY 2019-20

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 139Section 147Section 148Section 148ASection 151ASection 250

21/03/2023 was passed by the ITO, Ward-1(1), Hyderabad, i.e., Jurisdictional Assessing Officer (JAO). Thereafter, the ITO, Ward-1(1), Hyderabad issued notice under section 148 of the Act, dated 21/03/2023. In compliance, the assessee company filed its return of income for the subject year on 12/10/2023, declaring ... Income 6 Bilwa Infrastructure Limited vs. ITO Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing Officer” (JAO), and the assessments are statutorily required to be as per the prescribed faceless

Bilwa Infrastructure Limited, Hyderabad vs. ITO., Ward-1(1), Hyderabad

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 1362/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 145Section 147Section 148Section 148ASection 151Section 151ASection 250

submitted that the assumption of jurisdiction by the AO for framing the impugned assessment suffered from two serious infirmities, viz., (i) that the notice under section 148 of the Act, dated 27/04/2022 was issued by the ITO, Ward-1(1), Hyderabad, i.e., Jurisdictional Assessing Officer (JAO), i.e., outside the faceless ... notified by the Government of India on 29/03/2022 under section 151A, and, thus, was bad and illegal; and (ii) that as the notice under section 148 of the Act, dated 27/04/2022 for the subject year, i.e., AY 2018-19 was issued by the AO beyond the period of three years

Abraham Nathaniel Addanki, Hyderabad vs. ITO., Ward-14(1), Hyderabad

ITA 1148/HYD/2025[2016-17]Status: DisposedITAT Hyderabad21 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1148/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Abraham Nathaniel Vs. Income Tax Officer, Addanki, Ward-14(1), Hyderabad. Hyderabad. Pan: Adqpa7546N

For Appellant: Smt. S. Sandhya, AdvocateFor Respondent: Shri K. Vinoth Kannan

Section 142(1)Section 143(3)Section 144BSection 147Section 148

bank account which was not disclosed by him in his return of income, initiated proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 31/03/2021 was duly served upon the assessee. In compliance, the assessee filed his return of income on 31/05/2021, which, however ... dated 30/03/2022. Elaborating on her contention, the Ld. AR submitted that as both the order under section 148A(d), dated 29/03/2023 and notice under section 148 of the Act, dated 29/03/2023 had been issued by the ITO, Ward-14(1), Hyderabad, i.e., the Jurisdictional Assessing Officer (JAO), therefore, the assessment

D.A.V. Educational Trust, Chennai vs. ITO, Exemption Ward-2, Chennai

In the result, the appeal of the assessee for AY 2017-18 is allowed

ITA 1670/CHNY/2024[2018-19]Status: DisposedITAT Chennai21 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 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 G. Baskar, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT

Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

four years from the end of the relevant assessment year. He submits that the end of the relevant assessment year is 31.03.2015 and notice under section 148 of the Act was issued on 31.03.2021. He argued vehemently that the notice under section 148 of the Act issued is beyond four ... Assessing Officer, in the original assessment proceedings, after considering the books of accounts and other details including the issues raised in the notice under section 148 of the Act, completed the assessment by accepting the returned income without making any addition. He argued that the assessee disclosed fully and truly

D.A.V. Educational Trust, Chennai vs. ITO, Exemption Ward-2, Chennai

In the result, the appeals filed by the assessee for AY 2014-15,

ITA 1669/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadish

Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

D.A.V. Educational Trust, Chennai vs. ITO, Exemption Ward-4, Chennai

ITA 1667/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

Abdul Salam Mohamed Yasin, Mumbai vs. DCIT Circle 17(1), Mumbai

In the result, the appeal of the assessee is allowed on legal grounds

ITA 7502/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Jan 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: 1. Assessment Year

Section 07Section 1Section 144Section 144BSection 147Section 148Section 148ASection 149(1)Section 151

24/07/2022 14. Actual date of notice u/s 148 28/07/2022 4. From the aforesaid chronology, it is an admitted position that the original notice under section 148 under the erstwhile regime was issued on 30.06.2021, i.e., the very last day of the extended limitation period made available under the Taxation ... clarified that the legal fiction created in Ashish Agarwal stopped the clock of limitation with effect from the date of issuance of notices under section 148 under the old regime, which also became the date of issuance of the deemed notices under section 148A(b). The Hon’ble Supreme Court