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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

Rohan Promotors Pvt. Ltd., New Delhi vs. ITO Ward - 21(3), New Delhi

In the result, assessee’s appeal in ITA No

ITA 4849/DEL/2019[2007-08]Status: DisposedITAT Delhi31 Dec 2025AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

Section 142(1)Section 143(1)Section 147Section 148Section 271(1)(c)

Delhi on the alleged fact of accommodation entries made by the assessee, the matter was reopened under Section 147 of the Act and notice under Section 148 of the Act was issued on 20.03.2014 followed by notice under Section 142(1) on 17.07.2024. The Assessment under Section 147/144

M/S Rohan Promotors Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result, assessee’s appeal in ITA No

ITA 968/DEL/2017[2007-08]Status: DisposedITAT Delhi31 Dec 2025AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

Section 142(1)Section 143(1)Section 147Section 148Section 271(1)(c)

Delhi on the alleged fact of accommodation entries made by the assessee, the matter was reopened under Section 147 of the Act and notice under Section 148 of the Act was issued on 20.03.2014 followed by notice under Section 142(1) on 17.07.2024. The Assessment under Section 147/144

Raj Kumar Singh, Patna vs. ITO, Ward-6(4), Patna

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

ITA 341/PAT/2025[2016-17]Status: DisposedITAT Patna30 Dec 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 144Section 250

filed any return of income, the proceeding under section 147 of the Income Tax Act, 1961 (“the Act”) were initiated by issuing notice under section 148 of the Act. Since there was no compliance by the assessee, the total income was assessed at ₹77,72,460/- vide order under section

Ipf Vikram India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Circle, Panchkula

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

ITA 1204/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh30 Dec 2025AY 2014-15

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

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 148

account of employee benefits which was not added back to the taxable income. Believing this amount had escaped assessment, the AO issued a notice under section 148 on 30/03/2021. In response, the assessee filed a return on 27/04/2021, declaring a revised total income of Rs. 6,09,83,270/-. During ... considering the submissions of the assessee and the material on record, upheld the validity of reopening under section 147 by observing that the notice under section 148 was issued on the basis of audit information and that no earlier assessment had been completed for the relevant year. Accordingly, the challenge

Integrated Service Point Ltd., Chennai vs. ACIT, CC-2(4), Chennai

ITA 1883/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Pvt. Ltd.,) Vs. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषण की तारीख / Date Of Pronouncement : 13.10.2025 : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

Based on the submissions and computations made, the assessee submitted that the income disclosed in the return filed in response to the notice under section 148—amounting to Rs. 2,83,13,380/- for A.Y. 2019-20—and the revised statement of total income, which included an additional amount

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1882/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

Based on the submissions and computations made, the assessee submitted that the income disclosed in the return filed in response to the notice under section 148—amounting to Rs. 2,83,13,380/- for A.Y. 2019-20—and the revised statement of total income, which included an additional amount

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

ITA 1881/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Dec 2025AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Chennai. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

Based on the submissions and computations made, the assessee submitted that the income disclosed in the return filed in response to the notice under section 148—amounting to Rs. 2,83,13,380/- for A.Y. 2019-20—and the revised statement of total income, which included an additional amount

ACIT, Chennai vs. Integrated Service Point Limited, Anna Nagar

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1879/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

Based on the submissions and computations made, the assessee submitted that the income disclosed in the return filed in response to the notice under section 148—amounting to Rs. 2,83,13,380/- for A.Y. 2019-20—and the revised statement of total income, which included an additional amount

ACIT, Nungambakkam vs. Integrated Service Point Limited, Anna Nagar

ITA 1876/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

Based on the submissions and computations made, the assessee submitted that the income disclosed in the return filed in response to the notice under section 148—amounting to Rs. 2,83,13,380/- for A.Y. 2019-20—and the revised statement of total income, which included an additional amount

ACIT, Nunagambakkam vs. Integrated Service Point Limited, Anna Nagar

ITA 1874/CHNY/2025[2016]Status: DisposedITAT Chennai30 Dec 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

For Appellant: Mr. Y. Sridhar, FCA
Section 132Section 132(4)Section 134(4)Section 250

Based on the submissions and computations made, the assessee submitted that the income disclosed in the return filed in response to the notice under section 148—amounting to Rs. 2,83,13,380/- for A.Y. 2019-20—and the revised statement of total income, which included an additional amount

Jayesh H. Sanghavi HUF, Mumbai vs. ITO Ward 33(1)(1), Mumbai

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

ITA 6784/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Dec 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 10(38)Section 144Section 147Section 148Section 151Section 68

return so filed was processed and attained finality. Subsequently, the assessment was sought to be reopened by issuance of notice under section 148 dated 09.07.2022. It is an admitted position on record that the said notice was issued after the expiry of three years from the end of the relevant ... have carefully considered the rival submissions and perused the material placed on record. At the outset, it is evident that the notice under section 148 has been issued on 09.07.2022 for assessment year 2016-17, clearly beyond the period of three years from the end of the relevant assessment year

Hemlata Mahendra Chavda, Mumbai vs. ITO, Ward 19(2)(2), Mumbai

In the result, the appeal filed by the assessee is allowed on legal grounds

ITA 6770/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 144Section 147Section 148Section 148ASection 151

chargeable to tax that had escaped assessment. Consequent thereto, an order under section 148A(d) was passed, followed by issuance of a fresh notice under section 148 on 26.07.2022. 3 Hemlata Mahendra Chavda 4. It is an undisputed and admitted position on record that the notice under section 148 dated ... Ramesh Bachulal Mehta (supra), dealing with Assessment Year 2016-17, the Hon’ble Bombay High Court has unequivocally held that where the notice under section 148 is issued after the expiry of three years from the end of the relevant assessment year, the sanction accorded by the Principal Commissioner

Ila Khimjibhai Dulla, Mumbai vs. Ward 41(4)(2), Kautilya Bhavan

In the result, the appeal of the assessee is allowed

ITA 6716/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Dec 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 54

such information, notice under section 148A(b) was issued on 31.03.2022, followed by an order under section 148A(d) and issuance of notice under section 148 dated 19.04.2022. It is an undisputed position on record that the notice under section 148 was issued beyond three years from ... sake of completeness and ready reference, the relevant provision of section 149(1)(b) is reproduced hereunder: “149. (1) No notice under section 148 shall be issued for the relevant assessment year,— (a) ……………………………………………………………….. (b) if three years and three months, but not more than five years and three months, have

Jasaram Kesramji Rathod, Navi Mumbai vs. ITO Ward 28(1)(1), Navi Mumbai

In the result, the Assessee‟s appeal is allowed

ITA 5687/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Dec 2025AY 2013-14

Bench: Shri Narender Kumar Choudhryassessment Year: 2013-14 Jasaram K. Rathod, Income Tax Officer, Shop No.1, Plot No.391, Ward-28(1)(1), Saidham Building, Vs. It Office, Sector 19, Opp: Jimmy Tower, Vashi Railway Station Building, Kopar Khairne, Navi Mumbai-400703. Navi Mumbai-400709. Pan : Aacpc3348K (Appellant) (Respondent) For Assessee : Shri Pritam Kulapkar, Ld. Ar For Revenue : Shri A.M.K. Mahadevan, Ld. Sr.Dr Date Of Hearing : 20-11-2025 Date Of Pronouncement : 30-12-2025 O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 23-07-2025 Impugned Herein Passed By National Faceless Appeal Centre (Nfac), Delhi (In Short „Nfac‟)/Ld. Commissioner Of Income Tax (In Short „Ld. Commissioner‟) U/S. 250 Of The Income Tax Act 1961 (In Short „The Act‟) For The Ay. 2013-14. 2. In The Instant Case, The Assessee Had Declared His Total Income Of Rs. 16,97,210/-By Filing His Return Of Income For The Year Under Consideration On Dt. 01-11-2013, Which Was Subsequently Reopened For Re-Assessment U/S. 147 Of The Act By Issuing Notice Dt. 30-03-2021 U/S. 148 Of The Act, Mainly On The Reason That The Assessee Though Made Cash Payment Of Rs. 22,50,000/-For Purchase Of Land With Shri Mahesh M. Munde & 11 Others, But Has Not Offered The Same For Taxation For The Ay. 2013-14. 2 3. The Assessee In Response Filed His Return Of Income On 05-01-2022, Declaring Total Income At Rs. 16,97,210/-As Declared Originally. The Said Return Filed By The Assessee Was Declared/Considered As Belated And/Or Filed After The Stipulated Time Given In The Notice Dt. 30-03-2021 U/S. 148 Of The Act I.E., Within Thirty Days And, Therefore, The Same Was Treated As „Nonest’ & Accordingly The Case Of The Assessee Was Finalized U/S. 144 Of The Act Making The Addition Of The Aforesaid Amount Of Rs. 22,50,000/- By Passing The Assessment Order Dt. 29-03-2022 U/S. 147 R.W.S. 144B Of The Act.

For Appellant: Shri Pritam Kulapkar, Ld. ARFor Respondent: Shri A.M.K. Mahadevan, Ld. Sr.DR
Section 144Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 250

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

Shri Vipul Bansal, Mumbai vs. Income Tax Officer Ward 7(1)(2), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5628/MUM/2025[2010-11]Status: DisposedITAT Mumbai30 Dec 2025AY 2010-11

Bench: Shri Sandeep Singh Karhail & Shri Makarand Vasant Mahadeokar

Section 131Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 37(1)Section 69C

Rs.1,37,94,167/-. 3. Subsequently, the assessment was reopened under section 147 of the Act after obtaining approval of the competent authority. Notice under section 148 was issued on 21.09.2016 on the basis of information received from the Directorate of Investigation and Central Intelligence (DIT (I&CI)) through ... Ward 7(1)(2), Mumbai. According to the learned AR, the initiation of reassessment proceedings under section 147 and issuance of notice under section 148 by an officer lacking jurisdiction was void ab initio and went to the very root of the matter. 16. In support of Ground

Vaibhav Dwarkanath Warekar, Navi Mumbai vs. Income Tax Office, Navi Mumbai

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

ITA 5432/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Dec 2025AY 2011-12

Bench: Shri Sandeep Singh Karhailshri Makarand Vasant Mahadeokarvaibhav Dwarkanath Warekar 1 Midland Chs, Sector-9A Vashi, Navi Mumbai ............... Appellant Pan: Aalpw3682P

For Appellant: Shri Laxman SutarFor Respondent: Ms. Kavitha Kaushik, Sr.DR
Section 131Section 143(3)Section 147Section 148Section 250Section 69

derived income from salary, capital gains and income from other sources. However, the assessee did not file his original return of income. Accordingly, notice under section 148 of the Act was issued to the assessee on 26/03/2018, as the assessee had transactions in the multi-commodity exchange ... there were transactions in the multi- 5 commodity exchange apart from cash deposits in a bank account during the year under consideration, notice under section 148 of the Act was issued, and proceedings under section 147 of the Act were initiated. From the details filed during the assessment proceedings

Deepak Ghanshamdas Takhtani, Khar vs. Income Tax Ward Ward 22(1)(1), Mumbai

In the result, the appeal filed by the assessee stands allowed, and the impugned reassessment proceedings are hereby quashed

ITA 5382/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Adverting To The Merits Of The Addition, We Deem It Appropriate, As A Matter Of Judicial Propriety & Settled Legal Discipline, To First Examine The Jurisdictional Challenge Raised By The Assessee, Since If The Assumption Of Jurisdiction Itself Is Found To Be Infirm, The Entire Superstructure Of The Reassessment Would Necessarily Collapse.

Section 144Section 147Section 148Section 148ASection 151

deposited cash aggregating to ₹89,39,000/- in his bank account maintained with Canara Bank during the demonetisation period. Based on this information, notice under section 148 of the Act was issued on 28.07.2022 for the assessment year under consideration. 5. From a perusal of the notice placed ... paper book, it is evident that the said notice under section 148 was issued after obtaining approval of the Principal Commissioner of Income Tax-20, Mumbai, on 26.07.2022. Thereafter, an order 3 Deepak Ghanshamdas Takhtani under section 148A(d) was also passed, purportedly with prior approval of the Principal Commissioner

Shri Sanjay Haresh Mulchandani, Mumbai vs. Income Tax Officer Ward 19(3)(1), Mumbai

In the result, the assessee succeeds in the present appeal

ITA 4751/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Dec 2025AY 2011-12

Bench: Shri Narender Kumar Choudhryassessment Year: 2011-12 Shri Sanjay Haresh The Income Tax Officer, Mulchandani Ward, 19 (3) (1), 4-C Ajanta Apartments, M L Vs. Piramal Chamber, Dhanukar Marg, Peddar Road, Mumbai – 400013. Mumbai – 40026 Pan – Aadpm 3393 B (Appellant) (Respondent) Present For: Assessee By : Shri Harsh Kapadia & Nitin Khinchi, Ld. Ars Revenue By : Shri Sandeep Jumale, Ld. Sr. Dr Date Of Hearing : 20.11.2025 Date Of Pronouncement : 30.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 08.07.2025, 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. 2011-12. 2. In The Instant Case, The Assessee Along With His Uncle Had Purchased A Flat In Iscon Platinum, Ahmedabad On A Consideration Of Rs. 59,30,000/- Through Cheques. Subsequently, Search Under Section 132 Of The Act Was Conducted By The Investigation Wing, In The Case Of Jp Iscon

For Appellant: Shri Harsh Kapadia & Nitin KhinchiFor Respondent: Shri Sandeep Jumale, Ld. Sr. DR
Section 132Section 143(1)Section 147Section 148Section 250

showing total income of Rs.3266840/-. The return was processed under Section 143(1). The case was reopened under Section 147 vide notice under Section 148 dated 31.03.2019 against which return was filed by the assessee on 30.04.2019 declaring total income of Rs.32,66,840/- as shown in the original return

ACIT-2(1)(1), Mumbai vs. Avin Rajendrakumar Agrawal, Mumbai

In the result, the appeal filed by the Revenue as well as the cross objection filed by the assessee are dismissed

ITA 84/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Dec 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 144Section 147Section 148Section 68

scrip during the relevant previous year, the Assessing Officer recorded reasons to believe that income chargeable to tax had escaped assessment and issued notice under section 148 of the Act on 31/03/2021. 5. In response to the notice under section 148, the assessee filed return of income on 18/05/2021 declaring

Sh. Raj Kumar Chaudhary, Delhi vs. ITO Ward-34(5), Delhi

In the result, both the appeals of the assessee are allowed for statistical purposes only

ITA 3671/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue [Assessment Year: 2018-19] Shri Raj Kumar Chaudhary, Income Tax Officer, C-243, Sector-3, Dsidc Ward-34(5), Indl. Area Bawana, Vs Delhi. New Delhi-11003. Pan- Aewpk1980K Assessee Revenue

Section 144BSection 147Section 148Section 148ASection 249(3)Section 271A

that assessee had not filed his return of income for the AY 2018-19 and the assessee also did not respond to the notice under section 148 of the Act and no return was filed in response to the notice u/s 148 of the Act. It ITA Nos- 3671 & 3670/Del/2025 ... proceeding facility on the portal, and also E Mail is of Professional and he did not tell assesse about such Notice. Hence notice under section 148 of the Act was not received by the assessee. The Appellant came to know about the impugned order only when Penalty Notice u/s 271AAC