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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

Raghu Alekh Barli, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 915/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

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 ... contended that, in the present case, the assessee had failed to call in question the jurisdiction of the JAO, who had issued the notice under Section 148 of the Act within the stipulated period, and therefore, he cannot be permitted to raise such an objection for the first time before

Bikaram Pushpender, Hyderabad vs. ITO, Ward-9(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 1606/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

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 ... contended that, in the present case, the assessee had failed to call in question the jurisdiction of the JAO, who had issued the notice under Section 148 of the Act within the stipulated period, and therefore, he cannot be permitted to raise such an objection for the first time before

Sanzyme Private Limited, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 1487/HYD/2025[2019-2020]Status: DisposedITAT Hyderabad24 Dec 2025AY 2019-2020

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

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 ... contended that, in the present case, the assessee had failed to call in question the jurisdiction of the JAO, who had issued the notice under Section 148 of the Act within the stipulated period, and therefore, he cannot be permitted to raise such an objection for the first time before

Vijay Kumar Patil, Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our above observation

ITA 1328/HYD/2025[2017-2018]Status: DisposedITAT Hyderabad24 Dec 2025AY 2017-2018

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1328/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Vijay Kumar Patil Vs. Income Tax Officer Hyderabad Ward 7(1) Pan:Aqopp2830M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Sarang Shah राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 16/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: CA Sarang ShahFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 124Section 124(3)Section 147Section 148Section 148ASection 151A(1)

issued by the Jurisdictional Assessing Officer, Income Tax Officer Ward 7(1), Hyderabad under sections 148A(b), order under section 148A(d) and Notice under section 148, along with all consequential proceedings are vitiated, not according to law and notices and orders are liable to be set aside for lack ... 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

Lingamgunta Adilaxmi, Secunderabad vs. ITO., Ward-10(1), Hyderabad

Accordingly we have set aside the order of the Ld. CIT(A) and quashed the impugned assessment order. Following the same reasoning, all these three appeals filed by the assessee are also allowed in ...

ITA 1317/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Dec 2025AY 2015-16

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Y 1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) Pan:Amnpl4940M Hyderabad 915/Hyd/2025 Shri Raghu Alekh Barli Dy. Cit 2018-19 Hyderabad Circle 6(1) Pan:Ahjpa1085F Hyderabad 1487/Hyd/2025 Sanzyme Private Ltd Dy. Cit 2019-20 Hyderabad Circle 3(1) Pan:Aaacu2692R Hyderabad 1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1) Pan: Cebpp4471F Hyderabad िनधा""रती "ारा/Assessee By: Advocates Shri S. Rama Rao & Sashank Dundu & C.A. Kumar Pal Tated राज" व "ारा/Revenue By:: Shri Waseem Ur Rahman, Sr. Dr

For Appellant: Advocates Shri S. Rama Rao &For Respondent: : Shri Waseem UR Rahman, Sr. DR
Section 147Section 148Section 148A

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 ... contended that, in the present case, the assessee had failed to call in question the jurisdiction of the JAO, who had issued the notice under Section 148 of the Act within the stipulated period, and therefore, he cannot be permitted to raise such an objection for the first time before