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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

Income Tax Office, Ludhiana vs. Sri Guru Hargobind Educational Society, Ludhiana

In the result, appeal of the Revenue is dismissed

ITA 71/CHANDI/2025[2019]Status: DisposedITAT Chandigarh20 Jan 2026

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

For Appellant: Shri Sanjeev Gupta, C.A (Virtual Mode)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 10Section 144Section 147Section 148Section 251Section 270ASection 271ASection 69A

India, Bank of India and other accounts. Based on these inputs, the Assessing Officer reopened the assessment under Section 147 and issued notice under Section 148 dated 29.03.2023, pursuant to which the assessee filed a return on 19.04.2023 declaring nil income. During the reassessment proceedings, statutory notices under Sections

Suresh Kumar, Yamunanagar vs. ITO, W-4, Yamunanagar

In the result, appeal of the assessee is allowed

ITA 390/CHANDI/2023[215-16]Status: DisposedITAT Chandigarh20 Jan 2026

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Ajay Jain,CAFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR
Section 143(3)Section 147Section 151Section 28Section 56

issuance of notice under section 147/148 was held to be valid. 43. Therefore, it is clear that necessary sanction for issuance of notice under section 148, as required under section 151 had been obtained" III. HIGH COURT OF DELHI in the case of Principal Commissioner of Income

Suresh Vitthalrao Barge, Beed vs. Ward-1(5), Aurangabad

In the result, appeal of the Assessee is allowed as per the

ITA 1398/PUN/2025[2015-16]Status: DisposedITAT Pune20 Jan 2026AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Digambar Surwase, CAFor Respondent: Shri Umesh Phade, Addl.CIT
Section 143(3)Section 148Section 151Section 250Section 44ASection 56(2)Section 56(2)(viib)

facts and circumstances of case and in law, appellant submit that sanction given under section 151 of Income Tax Act, 1961 to issue notice under section 148 of Income Tax Act, 1961 is not a valid sanction. The sanction granted is without application of mind. Accordingly, the notice issued ... that an order passed in reassessment proceedings are bad in law in the absence of reasons recorded for bad in issuing a reopening notice under Section 148 of the Act being furnished to the assessee when sought for. It is axiomatic that power to reopen a completed assessment under

ITO WD-3(1), Kolkata vs. Perfect Wahers & Fasteners (P) Ltd, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2599/KOL/2025[2015-16]Status: DisposedITAT Kolkata20 Jan 2026AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 144BSection 147Section 148Section 148ASection 68

Apex Court decision are given below: "108. The Income Tax Act read with TOLA extended the time limit for issuing reassessment notices under Section 148, which fell for completion from 20 March 2020 to 31 March 2021, till 30 June 2021. All the reassessment notices under challenge in the present ... with TOLA will be available to the Revenue to complete the remaining proceedings in furtherance of the deemed notices, including issuance of reassessment notices under Section 148 of the new regime. The surviving or balance time limit can be calculated by computing the number of days between the date

Sandip Jhunjhunwala, Kolkata vs. DCIT, Central Circle 4(3), Kolkata

In the result, appeal of assessee is allowed and that of Revenue is dismissed”

ITA 2483/KOL/2025[2012-2013]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsian &For Respondent: Shri S.B. Chakraborthy, DR
Section 132Section 132(4)Section 133ASection 139(1)Section 143(3)Section 271(2)Section 271A

order of the Tribunal where it was observed that - Merely because an income has been offered by the assessee in response to the notice under section 148, it cannot be ipso facto inferred that the penal provisions of section 271(1)© are attracted. In order to apply the penal provisions ... simply rested its conclusion on the act of the assessee of having offered additional income in the return filed in response to notice under section 148 of the Act. As noted earlier, the additional income so offered by the assessee was done in good faith and, therefore, in our view

Vikash Agarwal, Kolkata vs. ITO Ward-3(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1810/KOL/2025[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri V.K. Shahoo, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 148Section 148ASection 149Section 149(1)(b)Section 151Section 3(1)

TOLA overrides Section 149 of the Income-tax Act only to the extent of relaxing the time limit for issuance of a reassessment notice under section 148; d. TOLA will extend the time limit for the grant of sanction by the authority specified under section 151. The test to determine ... weeks allowed to the assesses to respond to the show cause notices; and h. The assessing officers were required to issue the reassessment notice under section 148 of the new regime within the time limit surviving under the Income-tax Act read with TOLA. All notices issued beyond the surviving

Prakasam Krishnamoorthy, Tiruchirappalli vs. ITO, Ward-1(1), Trichy

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

ITA 3177/CHNY/2025[2017-18]Status: DisposedITAT Chennai20 Jan 2026AY 2017-18

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3177/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18

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

Jeyaraman Johnson Kumar, Trichy vs. ITO, Ward 1(1), Trichy

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

ITA 3127/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Jan 2026AY 2020-21

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3127/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Shri Jeyaraman Johnson The Income Tax Officer, Kumar, Vs. Ward 1(1), Plot No.3 & 4, Bharathi Nagar, Trichy 11Th Cross, Puthur, Trichy – 620 017. Pan: Ahipj 7887P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Y. Sridhar, Fca ""यथ" क" ओर से/Respondent By : Ms. R. Kavitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 20.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 20..01.2026

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

outset, we notice that the assessee has filed addition 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

Manackchand Aarthi, Kancheepuram vs. ITO, Ward-1, Kancheepuram

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

ITA 3112/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Jan 2026AY 2020-21

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3112/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Smt. Manackchand Aarthi, The Income Tax Officer, No.17/2A, Gandhi Road, Vs. Ward 1, Sriperumbudur, Kancheepuram Kancheepuram – 602 105. Pan: Caxpa 6225Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Y. Sridhar, Fca ""यथ" क" ओर से/Respondent By : Ms. R. Kavitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 20.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 20.01.2026

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 144BSection 147Section 148Section 148ASection 250

outset, we notice that the assessee has filed addition 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

ACIT, Parel Piramal Chamber vs. Bhavin Kumar Rameshkumar Jain, Parel

In the result, the appeal of the Revenue is dismissed

ITA 6174/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Jan 2026AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2019-2020

For Respondent: None
Section 132(4)Section 148Section 69CSection 80G

148A(b), an order under section 148A(d) was passed on 30.03.2023 03.2023, followed by issuance of notice under , followed by issuance of notice under section 148 on 31.03.2023 31.03.2023. Bhavin Kumar Rameshkumar Jain Bhavin Kumar Rameshkumar Jain 2.7 In response to the notice under section 148, the assessee filed ... response to the notice under section 148, the assessee filed In response to the notice under section 148, the assessee filed a return of income and voluntarily offered the amount of a return of income and voluntarily offered the amount of a return of income and voluntarily offered the amount

Sanjay Gopaldas Bajaj, Mumbai vs. ITO Ward-12(1)(1), Mumbai

ITA 5944/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Jan 2026AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

Section 139Section 139(1)Section 54

basis of the aforesaid information, the Assessing Officer recorded reasons to believe that income chargeable to tax had escaped assessment and, accordingly, issued notice under section 148 of the Act on 30.03.2021. In response thereto, the assessee filed his return of income on 10.04.2021. 2.1 During the reassessment proceedings ... Assessing Officer noticed that the salary income of ₹60,95,500/- was duly declared in the return filed in response to the notice under section 148 and, therefore, no separate addition was made on that count. With regard to rental income of ₹12,00,000/-, it was observed that

Rohit Goel, Delhi vs. DCIT, CC-20, Delhi

Appeal is allowed in above terms

ITA 8320/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 8320/Del/2025 : Asstt. Year: 2017-18 Rohit Goel, Vs Dcit, The Tax Chambers, Central Circle-20, Advocates & Legal Advisors, New Delhi-110055 C-177, Defence Colony, Lgf, New Delhi-110024 (Appellant) (Respondent) Pan No. Amvpg5611Q Assessee By: Ms. Swati Talwar, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)-27, New Delhi’S Din & Order No. Itba/Apl/M/250/2024-25/1073465261(1) Dated 19.02.2025, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Ms. Swati Talwar, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

petitioner’s case that the said notice is barred by limitation. 9. It is material to note that the original notice under Section 148 of the Act [deemed to be a show cause notice under Section 148A(b) of the Act in terms of the decision in the case ... Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 [TOLA]. Thus, the AO had two days to issue the notice under Section 148 of the Act after receiving the reply dated 08.06.2022 filed by the petitioner. Since the said period was less than seven days

Ajay Nagpal, Delhi vs. ITO, Ward-48(1), Delhi

Appeal is allowed in above terms

ITA 8145/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Jan 2026AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 8145/Del/2025 : Asstt. Year: 2018-19 Ajay Nagpal, Vs Income Tax Officer, 15/10, East Patel Nagar, Ward-48(1), New Delhi-110008 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpn9871D Assessee By: Sh. Pranav Yadav, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2018-19 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081608419(1) Dated 09.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Pranav Yadav, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

petitioner’s case that the said notice is barred by limitation. 9. It is material to note that the original notice under Section 148 of the Act [deemed to be a show cause notice under Section 148A(b) of the Act in terms of the decision in the case ... Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 [TOLA]. Thus, the AO had two days to issue the notice under Section 148 of the Act after receiving the reply dated 08.06.2022 filed by the petitioner. Since the said period was less than seven days

Reshma Harbakhsh Singh Through Legal Heir Sh. Vikramaditya Singh, New Delhi vs. DCIT, Circle-28(1), Delhi

In the result, appeal of the assessee is allowed

ITA 6289/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Jan 2026AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Smt. Renu Jauhri, Hon’Ble

For Appellant: Shri Pranshu Goel, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 144Section 147Section 148Section 148ASection 151Section 250Section 271(1)(C)

assessments. The provision imposes a responsibility on the Revenue to ensure that it obtains the sanction of the specified authority before issuing a notice under Section 148. The purpose behind this procedural check is to save the assesses from harassment resulting from the mechanical reopening of assessments. 128 A table ... year. Thus, non-compliance by the assessing officer with the strict time limits prescribed under Section 151 affects their jurisdiction to issue a notice under Section 148. 77. Parliament enacted TOLA to ensure that the interests of the Revenue are not defeated because the assessing officer could not comply with

Anwesh Kumar Chakraborty, Kolkata vs. Assessing Officer, Jamshedpur

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

ITA 207/RAN/2025[2015-16]Status: DisposedITAT Ranchi19 Jan 2026AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay(Virtual Hearing) Anwesh Kumar Chakraborty, Assessing Officer, Flat No. 04, Ashabori Apartment, 11/1 Jamshedpur. Vs. Kolupara Lane, Dhakuria, Kolkata-700031 (West Bengal) Pan No. Aiqpc 6936 M Appellant/ Assessee Respondent/ Revenue

Section 10Section 144Section 144BSection 147Section 148Section 80D

DDIT(Systems), Ranchi that the assessee has claimed large refund. Thus, the Assessing Officer, after taking proper approval of the competent authority, issued notice under Section 148 of the Income Tax Act, 1961 (in short, the Act). However, notice under Section 148 of the Act was not complied

Shiv Shambhu Iron and Steel Private Limited, Jamshedpur vs. ACIT Circle 3(1), Jamshedpur

The appeal of the assessee is allowed for statistical purposes

ITA 286/RAN/2024[2011-12]Status: DisposedITAT Ranchi19 Jan 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.286/Ran/2024 Assessment Year: 2016-17 Shiv Shambhu Iron & Steel Pvt. Ltd.…….…............................……….……Appellant Dropadi Bhawan, Station Road, Jugsalai, Jharkhand- 831002. [Pan: Aalcs7663M] Vs. Acit, Circle-3(1), Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 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 12.04.2024 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 Filed Its Return Of Income For The Assessment Year 2011–12 Declaring A Total Income Of ₹30,17,990. The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Of The Act Was Completed Determining The Total Income At ₹39,08,910. Subsequently, Based On Information Received, It Was Noticed That The Assessee Company Had Shown Receipt Of ₹1,49,00,000 Comprising Share Capital Of ₹14,90,000 & Share Premium Of ₹1,34,10,000. On The Basis Of This Information, The Assessing Officer Issued Notice Under Section 148 Of The Act. In Response To The Notice, The

Section 143(3)Section 147Section 148Section 250

capital of ₹14,90,000 and share premium of ₹1,34,10,000. On the basis of this information, the Assessing Officer issued notice under section 148 of the Act. In response to the notice, the I.T.A. No.286/Ran/2024 Shiv Shambhu Iron and Steel Pvt. Ltd assessee filed a return

Mohammed Wasim Akram, Madhepur, Barsoi, Katihar vs. ITO, Katihar

In the result, both the appeals are allowed for statistical purposes

ITA 465/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Sonjoy Sarmai.T.A. Nos.464&465/Pat/2025 Assessment Year: 2018-19 Mohammed Wasim Akram..……………… …………………....Appellant At/Po – Madhepur, Barsol, Ps-Telta, Katihar, Bihar- 854317.. [Pan: Bfcpa6650Q] Vs. Ito, Katihar……………….…..……………..………………….…..... Respondent Appearances By: Shri Nishant Gaurav, Ar, Appeared On Behalf Of The Appellant. Shri Manab Advak, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 आदेश / Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee & Are Directed Against Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Both Dated 14.08.2025. Ita No. 464/Patna/2025 Arises Out Of The Assessment Order Passed Under Section 147 Read With Section 144 Of The Income-Tax Act, 1961, Whereas

Section 144Section 147Section 148Section 271ASection 69A

noticed by the Assessing Officer that the assessee had deposited and withdrawn substantial amounts of cash in his bank account. Accordingly, notice under section 148 of the Act was issued. Despite issuance of statutory notices and opportunities provided by the Assessing Officer, the assessee remained non- compliant. Consequently, the Assessing

Mohammed Wasim Akram, Madhepur, Barsoi, Katihar vs. ITO, Katihar

In the result, both the appeals are allowed for statistical purposes

ITA 464/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Sonjoy Sarmai.T.A. Nos.464&465/Pat/2025 Assessment Year: 2018-19 Mohammed Wasim Akram..……………… …………………....Appellant At/Po – Madhepur, Barsol, Ps-Telta, Katihar, Bihar- 854317.. [Pan: Bfcpa6650Q] Vs. Ito, Katihar……………….…..……………..………………….…..... Respondent Appearances By: Shri Nishant Gaurav, Ar, Appeared On Behalf Of The Appellant. Shri Manab Advak, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 आदेश / Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee & Are Directed Against Two Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Both Dated 14.08.2025. Ita No. 464/Patna/2025 Arises Out Of The Assessment Order Passed Under Section 147 Read With Section 144 Of The Income-Tax Act, 1961, Whereas

Section 144Section 147Section 148Section 271ASection 69A

noticed by the Assessing Officer that the assessee had deposited and withdrawn substantial amounts of cash in his bank account. Accordingly, notice under section 148 of the Act was issued. Despite issuance of statutory notices and opportunities provided by the Assessing Officer, the assessee remained non- compliant. Consequently, the Assessing

Gaurab Kumar, Puraini Bazar vs. ITO Ward 3(4) Saharsa, Koshi Chowk Saharsa

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

ITA 461/PAT/2025[2018-19]Status: DisposedITAT Patna19 Jan 2026AY 2018-19

Bench: the CIT(A). However, the CIT(A) dismissed the appeal ex parte for non-compliance, without adjudicating the issues on merits. 4. Aggrieved by the order of the CIT(A), the assessee is in appeal before the Tribunal. 5. In the instant case, there is a delay of 100 days in filing the present

Section 139(1)Section 147Section 148Section 250Section 44A

Income-tax Act, 1961 for the assessment year 2018–19. Subsequently, the case was reopened under section 147 of the Act and notice under section 148 was issued on the basis of information regarding cash deposits amounting to 2 Gaurab Kumar ₹1,29,16,548 in a bank account maintained ... with Central Bank of India. In response to the notice under section 148 of the act was issued to the assessee and assessee filed his return of income declaring income from business and profession at ₹10,33,071, computed at the rate of 8% under section 44AD

Sanjeev Kumar, Muzaffarpur vs. Commissioner of Income Tax Appeal, Patna

Appeal of the assessee is allowed for statistical purpose,

ITA 458/PAT/2025[2015-16]Status: DisposedITAT Patna19 Jan 2026AY 2015-16

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 144Section 147Section 148Section 250Section 69A

alleged cash deposits of ₹1.61 crore in a bank account 2 Sanjeev Kumar purportedly maintained with State Bank of India (SBI). Accordingly, notice under section 148 of the Act was issued requiring the assessee to explain the source of such cash deposits and to file the return of income