“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

Kalpesh Ravjibhai Sojitra, Jasdan vs. The Income Tax Officer, Ward 2(1)(2), Rajkot

In the result, appeal filed by the assessee is allowed, in above terms

ITA 487/RJT/2025[2017-18]Status: DisposedITAT Rajkot08 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

For Appellant: Shri Brijesh Parekh, Ld ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR

Section 133(6)Section 142(1)Section 147Section 148Section 148ASection 68

High Court in its aforesaid order had held that after the formulation of the "e-Assessment of Income Escaping Assessment Scheme, 2022", the notice under Section 148 of the Act can only be issued by the FAO and not by the JAO. For the sake of clarity, the observations ... reads thus:- 35. Further, in our view, there is no question of concurrent jurisdiction of the JAO and the FAO for issuance of notice under Section 148 of the Act or even for passing assessment or reassessment order. When specific jurisdiction has been assigned to either

Alok Kumar Rungta, Lucknow vs. NFAC, Delhi

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

ITA 598/LKW/2025[2014-15]Status: DisposedITAT Lucknow08 Jan 2026AY 2014-15

Bench: Shri Kul Bharatassessment Year: 2014-15 Alok Kumar Rungta V. National Faceless Appeal B-40 Flat No.34 Manoram Centre Apartment Aliganj, Lucknow- Delhi. 226024. Pan:Ajqpr0755G (Appellant) (Respondent) Appellant By: Shri Vijay Prakash Agarwal, Advocate Shri Akshay Agarwal, Advocate Respondent By: Shri R. R. N. Shukla, Addl Cit(Dr) Date Of Hearing: 28 10 2025 Date Of Pronouncement: 08 01 2026 O R D E R

For Appellant: Shri Vijay Prakash Agarwal, AdvocateFor Respondent: Shri R. R. N. Shukla, Addl CIT(DR)

Section 1Section 143(3)Section 147Section 148Section 150(1)

Provision for cases where assessment is in pursuance of an order on appeal, etc. (1)Notwithstanding anything contained in section 149, the notice under section 148 may be issued at any time for the purpose of making an assessment or reassessment or re-computation in consequence of or to give

Income Tax Officer, Khanna vs. Rohit Gupta, Khanna

In the result, the appeal filed by the Revenue is dismissed

ITA 861/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh08 Jan 2026AY 2015-16

Bench: it is finally disposed of.

For Appellant: NoneFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 144Section 147Section 148Section 251(1)(a)Section 69

basis of the said information, proceedings under section 147 of the Income Tax Act, 1961, were initiated, and a notice under section 148 was issued. Since the assessee failed to comply with the statutory notices issued under sections 148 and 142(1) of the Act, the Assessing Officer completed

Sanjay Champalal Jaiswal, Nanded-Waghala vs. ITO, Ward-1, Nanded-Waghala

In the result, appeal of the assessee is partly allowed

ITA 2136/PUN/2025[2016-17]Status: DisposedITAT Pune08 Jan 2026AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2136/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Sanjay Champalal Jaiswal, V The Income Tax Officer, At Post, Hadsani, Mahur, S Ward-1, Nanded. Tq.Mahur, Nanded-Waghala, Maharashtra - 431721. Pan: Awlpj7783Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Govind Prasad Mandala (Through Virtual) Revenue By Shri Madhukar Anand – Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2016-17 Dated 18.07.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 29.03.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149Section 250Section 69A

No.2136/PUN/2025 [A] 4. Section 149 of the Income Tax Act, 1961 is reproduced here as under : “149. Time limit for notice.— (1) No notice under section 148 shall be issued for the relevant assessment year,— (a) if three years have elapsed from the end of the relevant assessment year, unless ... held as under : Quote “9. A perusal of Section 151(i) would show that, the specified authority for the purpose of issuing notice under Section 148 within a period of three years from the end of the relevant assessment year is, the Principal Commissioner or Principal Director or Commissioner

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT

Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

which would govern the facts and circumstances of the case in the hands of the Assessing Officer. In the present case, the impugned notice under Section 148 of the I.T, Act was issued to the petitioner on 29 March, 2019. The petitioner received a copy of 'reasons to believe' furnished ... assessee's failure to disclose true, proper and complete facts in the return of income, filed for the subject assessment year. Accordingly, notice under Section 148 was issued. 14. Thus, on the perusal of such reasons, it is quite clear that the provisions of Section 153A providing for "Assessment

Shriram Finance Ltd., Chennai vs. PCIT, Chennai

ITA 2043/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2043/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Shriram Finance Limited, Vs. The Principal Commissioner Of [Since Shriram City Union Finance Income Tax – 3, Limited Amalgamated With Shriram Chennai. Transport Finance Co. Limited & Presently Known As Shriram Finance Limited], Sri Towers, Plot No. 14A, South Phase, Industrial Estate, Guindy, Chennai 600 032. [Pan:Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 15.10.2025 घोषणा की तारीख /Date Of Pronouncement : 08.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 3, Chennai For The Assessment Year 2022-23 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri C.N. Bipin, CIT

Section 143(3)Section 234DSection 263Section 36(1)(vii)Section 36(1)(viia)Section 4

writ petition and remanded back the matter, with liberty to the appellant to raise objections before the Assessing Officer who issued the notice under Section 148 of the IT Act, 1961 and a direction to the Assessing Officer to deal with the same in accordance with law after giving

Apcotex Industries Limited, Raogarh vs. Income Tax Officer - Circle 15(1)(1), Mumbai

In the result, having regard to the foregoing discussion and

ITA 6022/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Jan 2026AY 2013-14

Bench: Shri Amit Shuk

Section 143(3)Section 144BSection 147Section 148Section 148ASection 24Section 250Section 32

property. On this basis, proceedings under section 148A were initiated, and after passing an order under section 148A(d) dated 28.07.2022, notice under section 148 was issued on 29.07.2022. 4. In response to the notice issued under section 148 of the Income-tax Act, 1961, the assessee filed its return ... assessee challenged both the validity of reopening as well as the additions on merits. It was contended that the notice under section 148 was barred by limitation under section 149, that there was no failure on the part of the assessee to disclose fully and truly all material facts

Red Hat India Private Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

ITA 3016/MUM/2025[2011-12]Status: DisposedITAT Mumbai08 Jan 2026AY 2011-12

Section 143(3)Section 147Section 148Section 263Section 92C

transfer pricing adjustment, and the adjustments, if any, were confined to corporate tax issues. 5. Thereafter, reassessment proceedings were initiated by issuance of notice under section 148. The assessee objected to reopening, inter alia, on the ground that the royalty income had already been offered to tax through a revised

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 167/RAN/2025[2014-15]Status: DisposedITAT Ranchi07 Jan 2026AY 2014-15

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita No.165 & 167/Ran/2025 (निि ारण वर्ा / Assessment Year :2013-2014 & 2014-2015) Colen Chemical Pvt. Ltd, Vs. Ito Ward-1(1), Jamshedpur 1St Floor, Room No.9, Tiwary Bechar Complex, Main Rd. Bistupur, Jamshedpur-831001 स्थायी लेखा सं./Pan No. : Aabcc 3978 K (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Sunil Surana, Ar राजस्व की ओर से /Revenue By : Shri Ram Chandra Marndi, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख/Date Of Pronouncement : 07/01/2026 आदेश / O R D E R Per Bench : These Two Appeals Are Filed By The Assessee Against The Separate Orders Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Both Dated 31.03.2025 For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld.Ar That For The Assessment Year 2013- 2014 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29/01/2016 & For The Assessment Year 2014-2015 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29.12.2016. Notice U/S.148 Of The Act For A.Y.2013-2014 Came To Be Issued On 28.03.2018 & For A.Y.2014-2015 The Notice Was Issued On 24.06.2019. The Ld. Ar Drew Our Attention To Reason Recorded To Reopening For The Assessment Year 2013-2014 At Pages 47 To 51 Of The Paper Book Which Reads As Follows:-

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR

Section 143(3)Section 147Section 148

allegations of suppression of material fact. Under the circumstances, no error has been committed by the High Court in setting aside the reopening notice under section 148 of the Income-tax Act. We are in complete agreement with the view taken by the High Court. The special leave petition stands

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 165/RAN/2025[2013-14]Status: DisposedITAT Ranchi07 Jan 2026AY 2013-14

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR

Section 143(3)Section 147Section 148

Nityanand, Sant Kabir Nagar vs. Income Tax Officer, Basti

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 470/LKW/2025[2016-17]Status: DisposedITAT Lucknow07 Jan 2026AY 2016-17

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2016-17 Nityanand V. The Income Tax Officer Vill. & Post Dhamaicha Basti Sant Kabir Nagar (U.P) Tan/Pan:Agzpn3158R (Applicant) (Respondent) Applicant By: Shri Vikram Acharya, Aca Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 06.03.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2016-17. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Teacher Employed With The Government Of U.P. & Earned Salary Income. The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits To The Tune Of Rs.2,16,55,000/- In His Bank Account No.144200101001330 Maintained With Corporation Bank During The Year Under Consideration & The Cash Deposited By The Assessee During The Demonetization Period, I.E. From 01.04.2015 To 31.302.016 Was Rs.15,05,000/-. The Assessing Officer (Ao)

For Respondent: Shri R.R.N. Shukla, D.R

Section 115BSection 142(1)Section 143(3)Section 144Section 147Section 148Section 69A

reopened the case of the assessee under section 147 of the Income Tax Act, 1961 (hereinafter called “the Act’) after issuing notice under section 148 of the Act to the assessee. In response to the notice under section 148 of the Act, the assessee filed return of income

Dhirendra Pratap, Lucknow vs. Income Tax Officer-3(2), Ward-3(2), Hardoi

In the result, the appeal of the assessee stands allowed

ITA 467/LKW/2025[2011-12]Status: DisposedITAT Lucknow07 Jan 2026AY 2011-12

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2011-12 Dhirendra Pratap V. The Income Tax Officer A-16/1052, Sector 15 Ward 3(2) Near Vasundhra Complex Hardoi Indira Nagar, Lucknow (U.P) Tan/Pan:Ayepp3148C (Applicant) (Respondent) Applicant By: Shri Rakesh Garg, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 19.12.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2011-12. 2.0 The Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Year Under Consideration On 06.11.2018 Declaring A Total Income Of Rs.1,75,750/-. The Income Tax Department Was In Possession Of Information That The Assessee Had Deposited Cash To The Tune Of Rs.19,81,000/- In His Bank Account. The Assessing Officer (Ao) Issued A Query Letter Under Section 133(6) Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) On 04.01.2018, Requiring The Assessee To Furnish The Source Of Cash Deposits Along With Other Evidentiary Proof, In Response To Which The Assessee Filed Reply On 07.02.2018. Since

For Respondent: Shri R.R.N. Shukla, D.R

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 154Section 251Section 271(1)(c)

satisfied with the reply furnished by the assessee, he reopened the case of the assessee under section 147 of the Act after issuing notice under section 148 of the Act to the assessee. In response to the notice under section 148 of the Act, no return was filed ... dated 27.12.2024, raising a ground that the grounds raised by the assessee, challenging the initiation of assessment proceedings by sending the notice under section 148 of the Act dated 29.03.2018 have not been dealt with by the ld. CIT(A). The NFAC dismissed the application dated 27.12.2024 moved

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

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

ITA 517/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 144Section 147Section 148Section 148ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

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

ITA 462/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 144Section 147Section 148Section 148ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Deepti Social Service Society, Hindupur vs. ITO., Exemption Ward, Tirupati

ITA 920/HYD/2025[2018-19]Status: DisposedITAT Hyderabad07 Jan 2026AY 2018-19

Bench: Us:

Section 147Section 234ASection 69A

Jurisdictional Assessing Officer (JAO) erred in law and on facts in issuing the order under Section 148A(d) and the consequential reassessment notice under Section 148, whereas such notice is required to be issued only through the Faceless regime in accordance with Section 151A r.w.s.144B. The initiation of proceedings ... Officer (JAO), passed an order under section 148A of the Act, dated 01/04/2022, Page No.118 to 120 of APB. Thereafter, the JAO issued notice under section 148 of the Act, dated 01/04/2022. 4. As the assessee society had neither filed its return of income in compliance to the notice issued

Balguri Rajeshwar Rao, Hyderabad vs. ITO, Ward- 11(1), Hyderabad

ITA 1728/HYD/2025[2016-17]Status: DisposedITAT Hyderabad07 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1728/Hyd/2025

For Appellant: T Chaitanya Kumar, AdvocateFor Respondent: Helen Ruby Jesindha, Sr. AR

Section 133(6)Section 142(1)Section 147Section 148Section 148ASection 250Section 69A

NAGAR ALLWYN COLONY KUKATPALLY HYDERABAD 500072, Andhra Pradesh India PAN: AWQPB0668R A.Y: 2016-17 DATED: 27/03/2023 DIN & Notice No: ITBA/AST/S/148_1/2022- 23/1051397562(1) Notice under section 148 of the Income-tax Act, 1961 Sir/Madam/M/s. 1. I have the following information in your case or in the case of the person

Primary Agricultural Co Op Credit Society Limited Minarpally, Minarpally Village vs. Income Tax Officer, Ward-1, Nizamabad

ITA 140/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad07 Jan 2026AY 2016-2017

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.140/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2016-17) Primary Agricultural Vs. Income Tax Officer Cooperative Credit Society Ward 1 Ltd Minarpally, Minarpally Minarpally, Nizamabad Pan:Aabap7760J (Respondent) (Appellant) निर्धारिती द्वारा / Assessee By: C.A Akshay Surana राजस्व द्वारा / Revenue By:: Smt. Helen Ruby Jesindha, Sr. Dr सुनवाई की तारीख / Date Of Hearing: 22/12/2025 घोषणा की तारीख / Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Primary Agricultural Cooperative Credit Society Ltd Minarpally (“The Assessee"), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 05.11.2024 For The A.Y, 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal: Page 1 Of 18

For Appellant: C.A Akshay Surana

Section 147Section 148Section 148ASection 80P

under section 148 and the order passed under section 148A(d) of the Act. In this regard, the Ld. AR submitted that the notice under section 148 as well as the order under section 148A(d) of the Act were issued by the Jurisdictional Assessing Officer (“JAO”) instead ... CBDT Notification No. 18/2022 dated 29.03.2022, issued under section 151A(1) and (2) of the Act, mandates that with effect from 29.03.2022, all notices under section 148 of the Act must be issued through the Faceless Assessment Unit. Relying on the order of the Hon'ble jurisdictional High Court

Sanghi Textiles Private Limited, Hyderbad vs. ITO., Ward-3(1), Hyderabad

ITA 1311/HYD/2025[2014-15]Status: DisposedITAT Hyderabad07 Jan 2026AY 2014-15

Bench: Us:

Section 139(1)Section 143(2)Section 145Section 147Section 148Section 194ASection 250Section 37(1)

filed its return of income for the subject year, i.e., AY 2014-15, initiated proceedings under section 147 of the Act. Notice under section 148 of the Act, dated 27/03/2021, was issued to the assessee company. In compliance, the assessee company filed its return of income on 21/10/2021, declaring ... r.w.s 144B of the Act, dated 30/03/2022. Elaborating on his contention, the Ld. AR submitted that though the assessee company, in response to notice under section 148 of the Act, dated 27/03/2021, had filed its return of income for the subject year on 21/10/2021, declaring its income

Thalla Srisailam Goud, Ibrahimpatnam vs. Income Tax Officer, Ward 9(1), Hyderabad

In the result, the appeal of the assessee in ITA No

ITA 589/HYD/2024[2013-14]Status: DisposedITAT Hyderabad07 Jan 2026AY 2013-14

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Respondent: Ms. U. Mini Chandran, CIT-DR and Ms. Payal Gupta, SR-DR

Section 147Section 148

notice issued under section 148 of the Act. In this regards the Learned Authorised Representative (“Ld. AR”) submitted that although the notice under section 148 of the Act bears the date 31.03.2021, the same was, in fact, issued and communicated to the assessee only on 01.04.2021. In support of this ... email communication received by the assessee from the Revenue, placed at page no. 48 of the paper book no.1, whereby the notice under section 148 of the Act was served upon the assessee. The Ld. AR pointed out that the said email clearly reflects the time of delivery

Desu Enterprises, Ongole vs. ITO., Ward-1, Ongole

In the result, the appeal of the assessee in ITA No

ITA 549/HYD/2024[2015-16]Status: DisposedITAT Hyderabad07 Jan 2026AY 2015-16

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.549 & 589/Hyd/2024 (निर्धारण वर्ष/Assessment Years:2015-16 & 2013-14) 1. M/S. Desu Enterprises, Ongole (A.P.) Pan: Aagfd1940C 2. Thalla Srisailam Goud, Ibrahimpatnam. Pan: Αιτpg3044K (Appellants) Vs. Income Tax Officer, Ward-1, Ongole. Income Tax Officer, Ward 9(1), Hyderabad. (Respondents) निर्धारिती द्वारा / Assessees By: राजस्व द्वारा / Revenue By: Shri Sashank Dundu, Advocate Ms. U. Mini Chandran, Cit-Dr & Ms. Payal Gupta, Sr-Dr सुनवाई की तारीख / Date Of Hearing: 06/11/2025 घोषणा की तारीख / Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Appeals Are Filed By M/S. Desu Enterprises & Shri Thalla Srisailam Goud (“The Assessees”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 26.02.2024 & 09.04.2024 For The A.Ys. 2015-16 & 2013-14 Respectively. Since The Issues Involved In These Two Appeals Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Respondent: Shri Sashank Dundu, Advocate

Section 147Section 148