← All Phrases

“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

Adhimoolam Varadham Murugan, Tiruvallur vs. ITO, Ncw-5(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 2755/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Jan 2026AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2755/Chny/2025 िनधा%रण वष% /Assessment Year: 2015-16

For Appellant: Mr. H.Yeshwanth Kumar, C.A *+For Respondent: Ms. Latchana, CIT
Section 147Section 148Section 148ASection 250Section 69A

assessment, or re- computation of income shall be carried out under Section 147 of the Act. It further provides that the issuance of notice under Section 148 of the Act shall be through automated allocation, in accordance with the risk management strategy formulated by the Board as referred

Poonam Manoj Agrawal, Mumbai vs. Income Tax Officer, WD-25(3)(1), Mumbai

In the result, the Assessee’s Appeal is allowed

ITA 6018/MUM/2025[2016-17]Status: DisposedITAT Mumbai07 Jan 2026AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2016-17 Poonam Manoj Agrawal, Income Tax Officer, Wd- G-1801, Gundecha Gardens, 25 (3) (1), Bombay Gaswork Lane, Opp. Vs. Kautilya Bhavan, Bandra Ganesh Talkies, Lalbaug, Kurla Complex, Bandra, Mumbai - 400012 Mumbai - 400051 Pan – Adtpa3423D (Appellant) (Respondent) Present For: Assessee By : Shri Saiprasad K. Ghosh, Ld. A.R. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 07.01.2026 Date Of Pronouncement : 07.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 18.07.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In This Case, The Notice Dated 07.05.2021 Under Section 148 Of The Act Was Initially Issued Under The Old Act, Which Was Treated As Deemed Notice Under Section 148 (A)(B) Of The Act, In View Of The Judgment Of The Hon’Ble Apex Court In The Case Of Uoi Vs. Rajeev Bansal Reported {[2024] 167 Taxmann.Com 70} By Taking Sanction, As Per Old Provisions Of The Act, As Applicable Thereto.

For Appellant: Shri Saiprasad K. Ghosh, Ld. A.RFor Respondent: Shri Virabhadra Mahajan, SR. D.R
Section 148Section 151Section 250

case, the notice dated 07.05.2021 under Section 148 of the Act was initially issued under the old Act, which was treated as deemed notice under Section 148 (A)(b) of the Act, in view of the judgment of the Hon’ble Apex Court in the case of UOI Vs. Rajeev

Kaishar Interiors Private Limtied, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(2)(2), Mumbai

Accordingly Ground No.16 raised by the Assessee is allowed

ITA 5665/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh Kukreja &For Respondent: Shri Hemanshu Joshi
Section 143(3)Section 147Section 148Section 14A

Officer [1999] 236 ITR 34 (SC) it was held by the Hon’ble Supreme Court that at the stage of issuance of notice under Section 148 of the Act for initiating reassessment proceedings under Section 147 of the Act prima facie there must be some material on the basis ... Assessee at the time of recording reasons for reopening assessment on the basis of such material at the stage of issuance of notice under Section 148 of the Act. 12. In view of the above, we reject the challenge mounted by the Assessee to the validity of the reassessment proceedings

Nadeem Mohammed Iqbal Patni, Mumbai vs. ITO Ward 25(3)(1), Mumbai

ITA 5549/MUM/2025[2015-16]Status: DisposedITAT Mumbai07 Jan 2026AY 2015-16

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri M. SubramanianFor Respondent: Shri Pradipsinh Saktavat
Section 142Section 144BSection 147Section 148Section 148ASection 151

Regime as notice issued under Section 148A(b) of the New Regime and passed order under Section 148A(d) of the Act. Thereafter, notice under Section 148 of the New Regime was issued by the Assessing Officer Act between July and September, 2022. In the aforesaid background following issues came ... present case, re-assessment proceedings were initiated under the New Regime. Notice under Section 148A(b) of the Act as well as notice under Section 148 were issued under the New Regime. Therefore, it was contended by the Learned Departmental Representative that the judgment of Hon’ble Supreme Court

Assistant Commissioner of Income Tax-19(3), Mumbai vs. Rajen Kirtilal Shah, Mumbai

Accordingly, all the grounds raised by the Revenue are dismissed

ITA 5438/MUM/2025[2013-14]Status: DisposedITAT Mumbai07 Jan 2026AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dharmil JhaveriFor Respondent: Shri Annavaran Kosuri
Section 144Section 144BSection 147Section 68

Section 6 of the Direct Tax Vivad Se Vishwas Act, 2020 [Acknowledgement No.634768301270522, dated 27/05/2022.] 6. On 30/06/2021 the Assessing Officer issued the notice under Section 148 of the Act initiating reassessment proceedings for the same Assessment Year 2013-2014. According to the Assessing Officer as per the information received ... previous year. On the basis of the aforesaid information reassessment proceedings were initiated in the case of the Assessee. On 29/07/2022 the fresh notice under Section 148 and under Section 148A(d) of the Act as applicable with effect from 01/04/2021 was issued to the Assessee. It has been contended

Ashish Girish Jain, Mumbai vs. ITO, Ward 42(1)(1), Mumbai

ITA 5328/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh ShahFor Respondent: Shri Pradipsinh Saktavat
Section 132Section 143(1)Section 143(3)Section 147Section 148

that assessment year i.e. for A.Y. 2010-11 within the meaning of section 147 of the Income-tax Act, 1961." 4. The notice under Section 148 was duly served upon the Assessee. In response, vide letter dated 18/04/2015, the Assessee requested that income tax return filed on 29/07/2010 declaring total ... through from Rajendra and Dharamchand Group of cases. The reasons were recorded and prior approval from the concerned authority was taken before issuing notice under section 148 of the Act. As the case was reopened within a period of four years from the end of the relevant assessment year

Rajeev Kumar Mittal, Hisar vs. ITO, Ward-1, Hisar

In the result, the appeal of assessee is allowed

ITA 5229/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2018-19 Rajeev Kumar Mittal S/O Ram Vs. Income Tax Officer, Niwas Mittal, H. No. 103, Ward-1, Housing Board Colony, Sirsa Hisar Road, Hisar (Haryana) Pin: 125 001 Pan No. Aldpm6294Q (Appellant) (Respondent)

For Appellant: S/Shri Prem Rajpal & Pulak RajpalFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 250Section 270A

relevant assessment year to substantiate such total transactions of Rs.8,75,15,910/- (8,72,89,905 +1,49,605+76,400/-), a notice under Section 148 of the Act was issued to the assessee on 30.03.2022. In response to the notice, the assessee has not filed his return

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, Appeal of the Assessee is allowed

ITA 5053/DEL/2025[2014-15]Status: DisposedITAT Delhi07 Jan 2026AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 144BSection 147Section 148Section 148ASection 250Section 68

perusal of the Ld. CIT(A) order, we have noticed that no finding has been returned with respect to the plea of notice under section 148 of the Act being barred by limitation. Further, it is noticed that the Ld. CIT(A) has presumed that all the notices have been ... outset, Ld. AR has referred page No. 1 of the paper book filed before us containing the table for calculation of time barred notice under section 148 of the Act. It was argued that the case is covered by the judgment of Hon'ble Supreme court of India in Union

M/S Jhs Svendgaard Laboratories Ltd., New Delhi vs. DCIT CC-31, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

That on the facts and circumstances of the case, the reassessment proceedings initiated are bad in law as the notice under section 148 of the Act dated 25.03.2022 was issued by the Jurisdictional Assessing Officer in violation of provisions of section 151A of the Act, read with Notification No. 18/2022 ... Assessee. 12. The Assessee has raised Ground No. 4 contending that ‘the reassessment proceedings initiated are bad in law as the notice under section 148 of the Act dated 25.03.2022 was issued by the Jurisdictional Assessing Officer in violation of provisions of section 151A of the Act, read with Notification

ACIT Circle-28(1), New Delhi vs. Munjal Holdings, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5834/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 250Section 68

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 representing ... 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

Bholenath Foods Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle- 4(2), New Delhi

The appeal of the assessee is disposed of in above terms

ITA 5777/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Jan 2026AY 2012-13

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwalassessment Year : 2012-13 Bholenath Foods Limited, Vs. Income Tax Officer, Shop No.208, Ward 47(1), Bldg. No.2612/13, Naya Bazar, New Delhi. Delhi – 110 006. Pan: Aabcb3842P

For Appellant: Shri Shivam Yadav, Advocate &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 250Section 68

merely on the basis of the statement recorded during the course of the survey on the third party. 8. That the notice under section 148 of the Act is issued only on the basis of the statement of Shri. Ram Prakash Bhatia, without any independent application of mind

Global Emerging Markets India Limited, New Delhi vs. NFAC, New Delhi

In the result, the appeal of the assessee is allowed

ITA 4050/DEL/2024[2013-2014]Status: DisposedITAT Delhi07 Jan 2026AY 2013-2014

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshglobal Emerging Markets Assessment Unit, India Limited, Income Tax Department, B-28, Pushpanjali Farms, Vs. Nfac. Bijwasan. Pan-Aaacg3233C (Appellant) (Respondent) Appellant By Ms. Prem Lata Bansal, Sr. Adv. & Shri Shivang Bansal, Adv. Respondent By Shri Rajesh Kumar Dhaneshta, Sr. Dr Date Of Hearing 03.12.2025 Date Of Pronouncement 07.01.2026

Section 139(1)Section 147Section 148Section 148ASection 149Section 149A

take a decision under Section 149A(d) based on the available material and the reply of the assessee; and (iii) issue a notice under Section 148 if it was a fit case for reassessment. Once the clock started ticking, the assessing officer was See State ... surviving time limit, as prescribed under the Income Tax Act read with TOLA, was available to the assessing officers to issue the reassessment notices under Section 148 of the new regime. 112. Let us take the instance of a notice issued on 1 May 2021 under the old regime

Sunil Kumar, Bokaro vs. ITO, Ward-3(1), Bokaro

In the result, this appeal of the assessee is allowed

ITA 76/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaysunil Kumar, I.T.O., 255, Jora Mandir Road, Chas, Ward-3(1), Vs. Bokaro-827013 (Jharkhand) Bokaro. Pan No. Alypk 0473 A Appellant/ Assessee Respondent/ Revenue

Section 148Section 148A

IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY

Prawin Kumar, Ranchi vs. ITO, Ward 2(1), Ranchi

In the result, this appeal of the assessee is allowed

ITA 49/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayprawin Kumar, I.T.O., 3/B Rai Enclave, Harihar Singh Road, Ward-2(1), Vs. Ranchi-834008 (Jharkhand) Ranchi. Pan No. Ajapk 4541 M Appellant/ Assessee Respondent/ Revenue

Section 148Section 148A

IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY

Bijoy Kumar Agarwal, Ranchi vs. ACIT/DCIT Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 310/RAN/2025[11-12]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri Sonjoy Sarmaandshri Ratnesh Nandan Sahay, Accountantmember

Section 133(6)Section 143(2)Section 147Section 148Section 250

earned bogus LTCG through penny stock I.T.A. No.310/Ran/2025 Bijoy Kumar Agarwal transactions, including transactions in the scrip of Global Capital Market Ltd. Notice under section 148 was issued, in response to which the assessee filed a return declaring the same income as originally returned. During the reassessment proceedings notice under

Smita, Ranchi vs. ITO Ward 3(4), Chaibasa

The appeal of the assessee is allowed

ITA 266/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 144BSection 147Section 148Section 151

that the assessee filed his return of income for the assessment year 2018–19 declaring total income of ₹6,07,870. Subsequently, a notice under section 148 of the Act was issued on the ground that the assessee had sold a flat for a consideration of ₹30 lakhs, whereas ... Rules, 1963 seeking admission of an additional legal ground, contending that the approval obtained under section 151 of the Act for issuance of notice under section 148 was never furnished to the assessee. Therefore, the reassessment proceedings are therefore bad in law. Further, the Assessing Officer adopted stamp duty valuation

Income Tax Officer, Ranchi, Jharkhand vs. Amba Carbonisation Pvt. Ltd., Ranchi, Jharkhand

In the result, the appeal of the revenue is dismissed

ITA 61/RAN/2024[2013-14]Status: DisposedITAT Ranchi06 Jan 2026AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.61/Ran/2024 Assessment Year: 2013-14 Ito, Ranchi………..…………….…….…...................................……….……Appellant Vs. Amba Carbonisation Pvt. Ltd ……....….…..….........……........……...…..…..Respondent 21, Ashok Bhawan, Kali Asthan Road, Ranchi, Jharkhand. [Pan: Aadca7460J] Appearances By: Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Appellant. Shri Devesh Poddar, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Revenue Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.01.2024 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 A Company Incorporated Under The Provisions Of The Companies Act & Is Engaged In The Business Of Manufacturing & Trading Of Special Smokeless Coal/Coke. The Assessee Also Derives Income By Way Of Interest On Bank Deposits. As Per Information Available With The Income-Tax Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions. It Was Further Observed That There Existed A Difference Between The Turnover Disclosed By The Assessee In The Return Of Income & The Total Credits Appearing In The Bank Accounts. On The Basis Of The Above Information, The Assessing Officer (Ao) Initiated Reassessment Proceedings By Issuing A Notice Under Section 148 Of The

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 250Section 270ASection 273B

credits appearing in the bank accounts. On the basis of the above information, the Assessing Officer (AO) initiated reassessment proceedings by issuing a notice under section 148 of the I.T.A. No.61/Ran/2024 Amba Carbonisation Pvt. Ltd Act dated 16.03.2021. Subsequently, without concluding or formally dropping the earlier reassessment proceedings ... issued another notice under section 148 of the Act dated 31.03.2021 for the same assessment year and on identical reasons, thereby initiating parallel reassessment proceedings. In response to the notices issued under section 148 of the Act, the assessee filed its return of income on 18.08.2021, declaring total income

Naveen Singh, Jamshedpur vs. Deputy Commissioner of Income Tax, Circle - 1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 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 12.09.2024 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 Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

return was processed under section 143(1) accepting the income as declared. Subsequently, the AO issued a notice under section 148 of the Act after recording reasons and obtaining sanction from the competent authority. The assessee did not respond to the notice under section 148. Thereafter, multiple notices under section

Bishnu Transport Company, Dhanbad vs. DCIT/ACIT, Circle-1, Dhanbad

In the result, the appeal of the assessee is allowed

ITA 401/RAN/2024[2011-12]Status: DisposedITAT Ranchi06 Jan 2026AY 2011-12

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 143(3)Section 147Section 148Section 151Section 151oSection 68

challenging the validity of the reassessment proceedings on the ground that the approval obtained under section 151 of the Act for issuance of notice under section 148 of the Act was granted in a mechanical manner without application of mind. The Ld. AR submitted the copy of the approval order ... have heard the rival submissions and perused the material available on record. Under section 151 of the Act mandates that before issuance of notice under section 148 of the Act, the Assessing Officer must obtain prior sanction of the specified authority, who must apply its independent mind to the reasons

Sitaram Sultania, Patna vs. DCIT/ACIT, Cir-6, Patna

Appeal of the assessee is partly allowed

ITA 11/PAT/2025[2010-11]Status: DisposedITAT Patna06 Jan 2026AY 2010-11

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI RAJESH KUMAR (Accountant Member)

Section 147Section 148Section 250Section 50CSection 50C(2)

Accord- ingly, the case of the assessee was reopened under Section 147 of the Act by issuing notice under Section 148 of the Act. The assessee computed Short Term Capital Gain and duly showed the same in the return of in- come. Finally, the Assessing Officer computed short term capital