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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

Chintan Harshad Kanakia, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, ground No.3 of appeal is allowed

ITA 2822/MUM/2025[2015-16]Status: DisposedITAT Mumbai01 Jan 2026AY 2015-16

Bench: Shri Pawan Singhsmt Renu Jauhriassessment Year: 2015-16 (Hybrid Hearing) Chintan Harshad Kanakia, Ito Ward 42 (1)(1) Room No. 103, Sacovar Apt., Sagar Complex, 703, Kautilya Bhavan, Vs. Saibaba Nagar, Borivali (W), Bkc, Mumbai -400051 Mumbai Pan – Agnpk6023E

Section 10(38)Section 132Section 143(2)Section 148Section 148ASection 151ASection 234BSection 254(1)Section 271(1)(c)

which is penny scrip and claimed exemption of Rs.68,40,897/-. The AO recorded reasons of reopening and proceeded for re-assessment. The notice under Section 148 was issued to assessee on 23.06.2021. After the decision of Hon’ble Apex Court in Union of India Vs Ashish Aggarwal ... Assessing Officer recorded, in absence of reply to said show cause notice order under Section 148A(d) was passed on 29.07.2022 and issued notice under Section 148. In response to notice under Section 148 dated 29.07.2022 the assessee filed his return of income on 13.08.2022. 3. The Assessing Officer after

Mrs. Ranjana, Mrizapur vs. Assessing Officer, NFAC, Delhi

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

ITA 505/LKW/2025[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2015-16 Mrs Ranjana V. The Assessing Officer Village Dewapur Pachwal Nafc Post Rajapur, Aamghat Mirzapur (U.P) Tan/Pan:Aoxpr7130M (Applicant) (Respondent) Applicant By: Shri Narendra Kumar Sahu, 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 31.03.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2015-16. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed Her Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Purchased An Immovable Property Valued At Rs.60,00,000/- . The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice To The Assessee Under Section 148 Of The Act. However, The Assessee Neither Responded To The Notice Under Section 148 Of The Act Nor Filed Any Return Of Income For The Year Under Consideration. The Assessing Officer (Ao)

For Respondent: Shri R.R.N. Shukla, D.R
Section 142(1)Section 147Section 148Section 250Section 69

hereinafter called “the Act’) after issuing notice to the assessee under section 148 of the Act. However, the assessee neither responded to the notice under section 148 of the Act nor filed any return of income for the year under consideration. The Assessing Officer (AO), ITA No.505/LKW/2025 Page

Dharm Raj Kushwaha, Unnao vs. Income Tax Officer -2(4), Unnao

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

ITA 494/LKW/2025[2018-19]Status: DisposedITAT Lucknow31 Dec 2025AY 2018-19

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2018-19 Dharm Raj Kushwaha V. The Income Tax Officer 2(4) 172, Saipur Sarauda Unnao Safpur Unnao (U.P) Tan/Pan:Bmepk6477L (Applicant) (Respondent) Applicant By: None 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 27.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2018-19. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Business Correspondent Of State Bank Of India & Ran A Customer Service Point (Csp). The Assessee Had Not Filed His Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Withdrawals Of Rs.1,36,10,616/- From The Current Account Maintained With The State Bank Of India, Received An Amount Of Rs.11,550/- As ‘Commission/Brokerage’ & ‘Insurance Commission’ During The Year Under Consideration. The Case Of The Assessee Was Reopened Under

For Respondent: Shri R.R.N. Shukla, D.R
Section 144Section 144BSection 147Section 148Section 194H

hereinafter called “the Act’) after issuing notice to the assessee under section 148 of the Act. However, the assessee neither responded to the notice under section 148 of the Act nor filed any return of income for the year under consideration. The Assessing Officer (AO), thereafter, issued statutory notices ... Appeals) has erred in confirming the impugned assessment order without considering the facts that the assessment proceedings were wrongly initiated by issuance of notice under section 148 of the Income Tax Act, 1961 as there was no such income escaped in the assessment year 2018-19. 7. Because on facts

Amar Diwakar, Kanpur Nagar vs. Dy. Commissioner of Income Tax, Circle-4, Kanpur

The appeal of the assessee stands allowed for statistical purposes

ITA 117/LKW/2025[2012-13]Status: DisposedITAT Lucknow31 Dec 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Amar Diwakar V. Dcit J0512, Avas Vikas Circle 4 Keshavpuram, Kalyanpur Kanpur Kanpur Nagar (U.P) Tan/Pan:Aiypd7324G (Applicant) (Respondent) Applicant By: Shri Pradeep Seth, 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 20.12.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2012-13. 2.0 The Brief Facts Of The Case Are That As Per Information Gathered By The Department From Network Management System (Nms) Portal, The Assessee Had Earned Salary Income Of Rs.17,50,162/- From Fiit Jee Ltd & Had Made Cash Deposit Of Rs.11,50,000/- In His Saving Bank Account During The Year Under Consideration. The Assessee Had Not Filed His Return Of Income For The Year Under Consideration. The Assessing Officer (Ao) Initiated Proceedings Under Section 147 Of The Income Tax Act, 1961 After Issuing Notice Under Section 148 Of The Act To The Assessee. In Response To The Notice Under Section 148 Of The Act

For Respondent: Shri R.R.N. Shukla, D.R
Section 133(6)Section 147Section 148Section 250Section 271(1)(c)Section 69A

income for the year under consideration. The Assessing Officer (AO) initiated proceedings under section 147 of the Income Tax Act, 1961 after issuing notice under section 148 of the Act to the assessee. In response to the notice under section 148 of the Act, ITA No.117/LKW/2025 Page

Vikas Jain, Kanpur vs. ACIT-CC 2(1)(1), Kanpur

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

ITA 434/LKW/2024[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR
Section 143(1)Section 147Section 148Section 151Section 156Section 48Section 50C

market value / stamp duty value. Therefore, the case was reopened under section 147 after the necessary approvals, by way of issue of notice under section 148 of the Income Tax Act. The information on the basis of which the case was reopened, was that the assessee who was a partner ... under section 139 of the Act and the provisions of section 147 had been invoked without looking into the assessment records. Since, the notice under section 148 had been issued on the premise that he had not filed his return of income, the reasons recorded were factually incorrect

Dharam Chand Agarwal, Kanpur (Uttar Pardesh) vs. Principal Commissioner of Income Tax, Kanpur- I

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

ITA 358/LKW/2024[2016-2017]Status: DisposedITAT Lucknow31 Dec 2025AY 2016-2017

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Dharam Chand Agarwal, Vs. Pr. Commissioner Of Income Tax, 14/75 D Gopal Vihar Civil Lines, Kanpur-I, U.P. Kanpur, U.P. Pan: Aanpa1942L (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Pr. Cit, Kanpur-1 On 31.03.2024 Under Section 263 Of The Income Tax Act, 1961, Wherein The Ld. Pcit Has Set Aside The Order Passed By The Ld. Ao On 28.03.2022 Under Section 147 R.W.S. 144B For The A.Y. 2016-17 & Directing Him To Pass A Fresh Assessment Order. The Grounds Of Appeal Are As Under:- “1. Because The Assessment Order U/S 147 R.W.S 144 Dated 28.03.2022, Which Has Been Set Aside U/S 263 Of The Act By The Impugned Order Passed By Pr. Cit, Itself Was Illegal & Was Not Enforceable Due To Various Infirmities In The Initiation & Conclusion Of Re-Assessment Proceedings, The Same Could Not Have Been Subjected To Revision U/S 263 Of The Act & Consequently The Impugned Order Is Bad In Law & Wholly Without Jurisdiction. Without Prejudice To The Aforesaid 2. Because The Pr. Cit Has Erred In Law & On Facts In Holding That The Assessment Order Dated 28.03.2022 Passed By The Assessing Officer, Nfac U/S 147 R.W.S 144B Of The Act Is Erroneous In So Far As It Is Prejudicial To The Interest Of Revenue & In Setting Aside The Same By Exercising His Revisionary Jurisdiction U/S 263 Of The Act.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 133ASection 147Section 148Section 263

taxman.com 43 (Delhi), to mean that if item of escaped income on the basis of which reasons were recorded for issue of notice under section 148 was not added in the assessment, then addition in respect of, “other item of income” discovered during reassessment proceedings would be invalid ... from which it could be concluded that the final order passed by the Assessing Officer in closure of proceedings initiated by issue of notice under section 148, would be invalid and bad in law, only because no addition had been made on account of the subject on which the reasons

Rajkumari Dhanuka, Kolkata vs. ITO, Ward 32(2), Kolkata

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

ITA 2260/KOL/2025[2012-2013]Status: DisposedITAT Kolkata31 Dec 2025AY 2012-2013

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2260/Kol/2025 Assessment Year: 2012-2013 Rajkumari Dhanuka,…………….………….…Appellant 113, Park Street, Kolkata-700016 [Pan:Adupd7020N] -Vs.- Income Tax Officer,……………………………..Respondent Ward-32(2), Kolkata, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri Anil Kochar, Advocate, Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 08, 2025 Date Of Pronouncing The Order: December 31, 2025 O R D E R

Section 139Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 68

give any valid reason to confirm that the assessee has escaped assessment within the meaning of section 147 of the Act and issued notice under section 148 without jurisdiction and ld. Addl./JCIT(Appeals) did not consider the submission of the 3 Rajkumari Dhanuka assesse and passed order. Therefore

Shree Krishna Gyanodaya Flour Mills Pvt. Ltd., Kolkata vs. ACIT, Central Circle 4(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2179/KOL/2025[2011-2012]Status: DisposedITAT Kolkata31 Dec 2025AY 2011-2012

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Shree Krishna Gyanodaya Acit, Central Circle 4(3) Flour Mills Pvt. Ltd. Aaykar Bhawan Poorva 15Th Floor, 46C, Chowringhee 110, Kolkata-700107, Vs. Road, Everest House, Kolkata- West Bengal 700071, West Bengal (Appellant) (Respondent) Pan No. Aahcs8774P Assessee By : Shri S.K. Tulsiyan, Ar Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 01.12.2025 Date Of Pronouncement: 31.12.2025

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 139(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 151(1)Section 153ASection 68

India Ltd. (supra). the Supreme Court has laid down the procedure as to the manner of dealing with the objections raised against the notice under section 148 of the Act. The Supreme Court has held that when a notice under section 148 of the Act is issued, the proper course

M/S. Miravelle Tradecomm Private Limited, Kolkata vs. ITO, Ward 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1946/KOL/2025[2018-2019]Status: DisposedITAT Kolkata31 Dec 2025AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1946/Kol/2025 Assessment Year: 2018-2019 M/S. Mirabelle Tradecomm Pvt. Limited,.……Appellant 85, Netaji Subhas Road, 3Rd Floor, Kolkata-700001 [Pan:Aabcm7418A] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-4(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri S. Jhajharia, A.R., Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 09, 2025 Date Of Pronouncing The Order: December 31, 2025 O R D E R

Section 115BSection 148Section 148ASection 68

Assessing Officer concluded that the case of the assessee was fit for issuance of notice u/s 148 of the Act and accordingly notice under section 148 was issued to the assessee on 21.03.2022. The assessee was specifically requested vide show- cause notice issued on 08.03.2023 to explain the flow/routing

DCIT, Circle-5(1), Kolkata vs. Hindusthan National Glass and Industrieslimited, Kolkata

In the result, the appeal of the Revenue is dismissed as being infructuous

ITA 338/KOL/2024[2011-12]Status: DisposedITAT Kolkata31 Dec 2025AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 148ASection 14ASection 250

inevitable conclusion that the reassessment action would not sustain. 23. We, accordingly, allow the instant writ petition and quash the impugned notice under Section 148 for A.Y. 2014-15 dated 31 March 2021. 7. In Uttam Value Steels Ltd. v. Assistant Commissioner of Income-tax [2024] 166 taxmann.com 493 (Bombay

Karnataka Telecom Department Employees Co-Operative Society Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle 1(4), Blr, Bangalore

In the result, appeals of Revenue in ITA Nos

ITA 1080/BANG/2025[2016-17]Status: DisposedITAT Bangalore31 Dec 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Years: 2016-17

For Appellant: Shri PR Suresh, CAFor Respondent: Shri N Balusamy, JCIT-DR
Section 143(3)Section 147Section 148Section 148ASection 149Section 250Section 80(2)(a)

have considered the rival submissions and carefully perused the materials placed on record. The undisputed facts are that the impugned notice under section 148 of the Act was issued on 29.06.2021 for Assessment Year 2016-17. It is also not in dispute that the reopening has been initiated beyond ... order U/s.148A(d) on 19-7-2022 and issued notice U/s.148 on 20-7-2022 - It was noted that time period for issuing notice under section 148 expired on 16-6-2022 - Whether thus, impugned notice issued on 20-7-2022, was beyond period of limitation

Assistant Commissioner of Income Tax, Mumbai vs. Surbhi Jewellers Private Limited, Mumbai

In the result, appeal filed by revenue stands dismissed

ITA 5447/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 148Section 148ASection 151Section 68

Whether, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that the notice under Section 148 dated July 31, 2022, for A.Y. 2017-18 was barred by limitation. 2. Whether, on the facts and in the circumstances ... apply "notwithstanding anything contained in the specified Act." Section 5 I.T.A. No. 5447/Mum/2025 3(1), therefore, overrides the time limits for issuing a notice under section 148 read with Section 149 of the Income-tax Act; d. TOLA does not extend the life of the old regime. It merely provides

Vaibhav Nandkishor Patil, Navi Mumbai vs. Income-Tax Officer 3 (4), Kalyan, Thane District

Appeal of the assessee is allowed

ITA 1672/MUM/2025[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Vaibhav Nandkishor Patil, Income Tax Officer 3 (4), Kalyan, C-602, Patel Heritage, Mumbai Sector, Kharghar Maharashtra -421301 Vs. Mumbai Maharastra-410210 (Pan: Amxpp0196M) (Appellant) (Respondent) Present For: Assessee : Shri Mehul Shah, Ca Revenue : Shri Praveen Salunkhe, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Addl/Jcit(A), Panchkula, Vide Order No. Itba/Apl/S/250/2024- 25/1073638541(1), Dated 24.02.2025, Passed U/S. 250 Of The Income- Tax Act, 1961 (Hereinafter Referred To As The “Act”) Against The Assessment Order U/S. 143(3) R.W.S. 147 By Ito Ward 3(2), Kalyan, Dated 23.02.2015, For Assessment Year 2011-12. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. On The Facts & In Circumstances Of The Case & In Law, Learned Commissioner Of Income-Tax (Appeal) Erred In Upholding Action Of The Assessing Officer In Disallowing The Entire Alleged Bogus Purchases Of Rs.15,47,224 Without Making Any Independent Inquiry By Treating The Purchases As Bogus In Nature On Mere Suspicion That The Parties Were Listed On Website Of Mvat

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Praveen Salunkhe, Sr. DR
Section 133(6)Section 142(1)Section 143(3)Section 148Section 250

were initiated, alleging that purchase of Rs. 15,47,224/- are accommodation entries and not genuine which has escaped assessment. Notice under section 148 was issued on 05.04.2013. 3 Vaibhav Nandkishor Patel AY 2011-12 Subsequently, statutory notices under Section 142(1) were issued on the assessee seeking explanation

Pallavi Kamal Shah, Mumbai vs. Income Tax Officer, Income Tax Department

In the result, appeal of the assessee is dismissed

ITA 6317/MUM/2024[2013-2014]Status: DisposedITAT Mumbai31 Dec 2025AY 2013-2014

Bench: Shri Pawan Singh& Smt. Renu Jauhri(Physical Hearing) Pallavi Kamal Shah Ito, Ward-30(1)(1), Mumbai A-601, Bhimsen Chs Ltd., Marve Vs Maharashtra-400051. Road, Malad West, Maharashtra - 400064. [Pan: Avops7447Q] Appellant / Assessee Respondent / Revenue

Section 124Section 142Section 143(2)Section 144Section 144BSection 144B(1)(xiv)Section 144B(1)(xvi)Section 147Section 148Section 254(1)

such information, the assessing officer was of the view that income of assessee has escaped assessment. The assessing officer after recording reasons issued notice under section 148 dated 18.02.2020. The assessing officer recorded that no compliance was made in response to notice under section 3 Pallavi Kamal Shah 148 ... held that assessee has could challenged the jurisdiction of ld. AO within 30 days from the service of notice under section 148. No such objection was raised by assessee. Thus, not eligible to raise such objection. However, legal issues that notice under section 143(2) was not issued

Mr Vinay Narayan Kedia, Mumbai vs. Income Tax Officer, Ward 22(3)(6), Mumbai

In the result, appeal filed by assessee stands allowed

ITA 5289/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 10(38)Section 147Section 148Section 148BSection 151Section 68

erred in upholding the action of the officer at the Assessment Unit hereinafter referred to as the Assessing Officer) in issuing notice under Section 148 of the Act. The appellant contends that on the facts and in the circumstances of the case and in law, the issue of notice under ... quashed. The appellant further, contends that on the facts and in the circumstances of the case and in law, the issue of notice under Section 148 dated 26.07.2022 has resulted into parallel/ simultaneous proceedings by the Department under Section 147 of the Act inasmuch as the proceedings of reassessment commenced

Anuj Kapoor, New Delhi vs. DCIT Circle-16(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 4098/DEL/2025[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh

Section 147Section 148Section 148ASection 68Section 69A

exclusions, the Assessing Officer will have sixty-one days (days between May 1, 2021 and June 30, 2021) to issue a notice under section 148 of the new regime. This time starts ticking for the Assessing Officer after receiving the response of the assessee. In this instance, if the assessee ... submits the response on June 18, 2022, the Assessing Officer will have sixty-one days from June 18, 2022 to issue a reassessment notice under section 148 of the new regime. Thus, in this illustration, the time limit for issuance of a notice under section 148 of the new regime

Harish Narang, Panipat vs. The Principal Commissioner of Income Tax, Rohtak

In the result, the appeal of the assessee is dismissed

ITA 3637/DEL/2025[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2018-19] Harish Narang, The Principal Commissioner Of H. No.238, Ward No.8, Income Tax, Rohtak, Panipat, Haryana-132103 Vs Aayakar Bhawan, Opp. Mansarover Park, Rohtak, Haryana-124001 Pan:Acvpn4090J Appellant Respondent Assessee By Shri Amit Kaushik, Adv. Revenue By Ms. Amisha S. Gupt, Cit(Dr) Date Of Hearing 16.10.2025 Date Of Pronouncement 31.12.2025

Section 144BSection 147Section 263Section 69C

basis of material available on record, it is decided that the case of Sh. Harish Narang is a fit case for issuance of notice under section 148 of the Act for A.Y. 2018-19. This order is passed with the prior approval of the Principal Commissioner of Income Tax, Rohtak

Genpact Services Llc, Gurgaon vs. ACIT, Circle - 1(3)(1), International Tax, New Delhi

In the result, appeal of the assessee is allowed

ITA 3480/DEL/2025[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 144C(13)Section 147Section 148Section 148ASection 149

authorities below. 4. We have heard both the parties and perused the material available on record. In this case, the original notice under section 148 of the Act, as per the unamended law was issued on 08.04.2021. Pursuant to the decision of Hon'ble Supreme Court in the case ... TOLA apply "notwithstanding anything contained in the specified Act." Section 3(1), therefore, overrides the time limits for issuing a notice under section 148 read with Section 149 of the Income-tax Act; d. TOLA does not extend the life of the old regime. It merely provides a relaxation

Manohar Filaments Pvt Ltd, Delhi vs. PCIT, (Central)-3, Delhi

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

ITA 2644/DEL/2025[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2016-17 ] Manohar & Filaments Pvt. `Vs. Pcit, (Central)-3, Delhi Ltd, B-59, G. T. Karnal Road, Industrial, Area, New Delhi Pan No.Aaacm1116E Appellant Respondent

Section 153CSection 153DSection 263

Revenue. In the present case, the Assessing Officer did not make any addition for the reasons recorded at the time of issue of notice under Section 148 of the Act. This position is not disputed and disturbed by the Commissioner of Income Tax in his order under Section

Assistant Commissioner of Income Tax, Delhi vs. The Indure Private Limited, Delhi

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

ITA 4640/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2013-14 Assistant Commissioner Of Vs. The Indure Private Limited, Income Tax, Indure House, Greater Kailash Part Ii, Delhi South Delhi 1100 48 Pan :Aaact0121C (Appellant) (Respondent)

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 250Section 69C

believe that income had escaped assessment within the meaning of section 147 of the Act. An order under Section 148A(d) and notice under Section 148 of the Act dated 28.07.2022 were issued. Notices under Section 143(2) of the Act copies under Section ... under Section 142(1) dated 27.12.2022 and 11.02.2023 were issued asking various details. The assessee filed part details on 20.02.2023. In response to notice under Section 148 of the Act, the assessee filed reply dated 29.07.2022, stating that due error shown on portal, the return of income could