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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

Gunmala Jain, Ajmer vs. Income Tax Officer, WD-2(2), Ajmer

Appeal of the assessee is dismissed

ITA 1262/JPR/2025[2019-20]Status: DisposedITAT Jaipur22 Dec 2025AY 2019-20

Bench: SMT. ANNAPURNA GUPTA, AM आयकर अपील सं. / ITA No.1262/JPR/2025 निर्धारणवर्ष / AssessmentYears :2019-20 Gunmala Jain, बनाम 28 Abhi Lash Nikunj, Kalyan Vs. Income Tax Officer, Ward-2(2) Colony, Ajmer Road Kekri, Ajmer स्थायीलेखा सं. / जीआईआर सं./ PAN/GIR No.: ABRPJ 4764E Ajmer अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assesseeby :Sh. Sunil Porwal, CA (Thr.V.C.) राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary (Addl. CIT) सुनवाई की तारीख / Date of Hearing : 18/1

For Appellant: Sh. Sunil Porwal, CA (Thr.V.C.)For Respondent: Sh. Gautam Singh Choudhary
Section 148Section 250Section 270ASection 80G

form of political donation of Rs.80,000/- made during the impugned year. Accordingly, the case of the assessee was reopened by issuing notice under Section 148 of the Act. In response to the said notice the assessee filed return of income withdrawing its claim of deduction under Section 80GGC ... there was no case of underreporting of income at all by the assessee, since, in the returned income filed in response to the notice under Section 148 of the Act, the assessee had not claimed any deduction under Section 80GGC of the Act on account of donations made to political

Madan Namdev Kamthe, Pune vs. Income Tax Officer Ward 5(2), Pune

In the result, appeal of the assessee is allowed

ITA 2410/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2410/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Madan Namdev Kamthe, V The Income Tax Officer, Plot No.43, S.No.22, Kojagiri S Ward-5(2), Pune. Sahakari Gruhrachana Society, Balajinagar, Dhankawadi, Pune – 411043. Pan: Asvpk9249G Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarvesh Khandelwal Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 18/12/2025 Date Of Pronouncement 22/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2019-20 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 R.W.S 144B Of The Act, Dated 04.03.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149Section 250Section 251Section 251(2)Section 271D

records. In this case, Assessee had filed return of income for A.Y.2019-20 declaring total income at Rs.5,75,540/-. Assessing Officer issued notice under section 148 dated 24.03.2023, then, Assessing Officer issued various notices. The Assessing Officer in the assessment order accepted that the immovable property sold is rural agricultural

Shri Anand Venkateshwara Developers, Pune vs. Income Tax Officer Ward 9(3), Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 2407/PUN/2025[2013-14]Status: DisposedITAT Pune22 Dec 2025AY 2013-14

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2407/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Shri Anand Venkateshwara V The Income Tax Officer, Developers, S Ward-9(3), Pune. S.No.23/2/1 B 5, S.No.23, H.No.2/1 B5, Anand Park, Thergaon Road, Pimpri, Pune – 411033. Maharashtra. Pan: Acnfs5707R Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas P Bora Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 18/12/2025 Date Of Pronouncement 22/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 29.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 30.03.2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 139(1)Section 147Section 148Section 149Section 250Section 56

interest of justice. ITA No.2407/PUN/2025 [A] Additional Grounds of appeal : Additional Ground No. 1 "The Ld. Assessing Officer erred in issuing notice under section 148 of the Income-tax Act, 1961 dated 31.03.2021 for Assessment Year 2013- 14, which is barred by limitation under section

Saravanan, Tiruppur vs. ITO, Ward-1(1), Tiruppur

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

ITA 2556/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Dec 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. S. Bhupendran, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 147Section 148Section 251(1)(a)

filed. 3. Without prejudice, the Learned Commissioner (Appeals) also erred in not considering that the Reassessment Proceeding was null and void, as the Notice under Section 148 dated 27/03/2021 was issued with the approval of the PCIT, Coimbatore-1, when the notice was issued within four years from

Saravanan, Tiruppur vs. ITO, Ward-1(1), Tirupur

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

ITA 2553/CHNY/2025[2014-15]Status: DisposedITAT Chennai22 Dec 2025AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. S. Bhupendran, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 147Section 148Section 251(1)(a)

filed. 3. Without prejudice, the Learned Commissioner (Appeals) also erred in not considering that the Reassessment Proceeding was null and void, as the Notice under Section 148 dated 27/03/2021 was issued with the approval of the PCIT, Coimbatore-1, when the notice was issued within four years from

Guthu Rithesh Rai, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(4), Bangalore

In the result appeal filed by the assessee is allowed for statistical purposes with above direction

ITA 790/BANG/2025[2014-15]Status: DisposedITAT Bangalore22 Dec 2025AY 2014-15

Bench: Shri Prashant Maharishiassessment Year : 2014-15

For Appellant: Shri Vinaya Simha, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 131Section 132Section 142Section 143Section 143(3)Section 148Section 69

income tax act before the learned CIT – A along with the additions on the merits. The first ground of the assessee that the notice under section 148 could not have been issued for the impugned assessment year to the assessee as the proceedings under section 153A/153C it should have been ... person searched in the search, was also rejected holding that assessee was not the searched person. The assessee also challenged that the notice under section 148 was not served on the assessee, the learned CIT appeal categorically held that it was served on the assessee on 31st of March

Kondragunta Seshu Babu, Yadgir vs. Income Tax Officer, Ward-1, Yadgir

In the result appeal filed by the assessee is allowed for statistical purposes

ITA 1831/BANG/2025[2019-2020]Status: DisposedITAT Bangalore22 Dec 2025AY 2019-2020

Bench: Shri Prashant Maharishiassessment Year : 2019-20

For Appellant: Ms. Sahana, AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 139Section 144Section 144BSection 147Section 148Section 69

found that during the financial year 2018 – 19 the assessee has purchased an immovable property for ₹ 1,248,000. The assessee was given notice under section 148, 142 (1), show cause notice under section 144 but the assessee did not apply. Assessee also did not file any return of income ... necessary facts and documents in support of his case if opportunity is granted. 6. Thus the learned authorized representative submitted that that notice under section 148 of the act dated 13 March 2023 is issued by the jurisdictional assessing officer and a copy of the notice is enclosed wherein

ACIT-CC-7(3), Mumbai vs. Infratech Builders and Agro Private Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 2362/MUM/2025[2009-10]Status: DisposedITAT Mumbai22 Dec 2025AY 2009-10

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2009-10 Asst. Commissioner Of Income Vs Infratech Builders & Agro Pvt. Tax Central Circle 7(2), Ltd. Mumbai 216 Shah & Nahar Industrial E, Room No.655, 6Th Floor Dr. E Moses Road Worli Aayakar Bhavan M.K. Road Mumbai 400018, Maharashtra Mumbai, Mumbai India, Mumbai Pan: Aabci7392B Appellant Respondent Present For: Appellant By : Shri Niraj Sheth, Advocate Respondent By : Shri Virabhadra S. Mahajan, Sr. Dr (Virtually Appeared) Date Of Hearing : 29.09.2025 Date Of Pronouncement : 22.12.2025 O R D E R Per Girish Agrawalthis Appeal Filed By The Revenue Is Arising Out Of The Order Cit(A),- 49, Itba/Apl/S/250/2024-25/1072911991(1) Mumbai Vide Order Dated 04.02.2025 Against The Assessment Order Passed U/S 143(3)/147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 13.12.2016 For A.Y. 2009-10. 2. Grounds Taken By The Revenue Are As Under: 1."On Facts & Circumstances Of The Case & In Law, The Ld.Cit(A) Erred In Holding That The Reopening Of The Assessment Under Section 147 Of The Income Infratech Builders & Agro Pvt. Ltd. A.Y.2009-10 Tax Act, 1961 Is Bad In Law Without Considering The Fact That The Assess Had Failed To Provide 1 The Details Of Payments Made To M/S. Bovis India Pvt. Ltd. & M/S. Bovis Lend Lease India Pvt. Ltd. & No Service Tax Was Charged On The Payments Made To These Companies, Unlike Other Similar Payments.”

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Virabhadra S. Mahajan, Sr. DR
Section 143(3)Section 147Section 80

come up with possibly a different conclusion and such an exercise is not permissible. 5. Also, it is a case where the notice under section 148 was issued beyond the period of four years from the end of the relevant assessment year, fact of which is undisputed. Original assessment under ... Taxman 725 (Punj. & Haryana) 6. Considering the factual matrix discussed above and the judicial precedents, the reopening proceedings initiated by issuing notice under section 148 and the impugned reassessment order passed thereafter are bad in law, being not in accordance with the provisions of the Act as discussed above, both

Town Educational Society, Ballia vs. Income Tax Officer, Ward - 2(4), Ballia

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

ITA 141/VNS/2024[2016-2017]Status: HeardITAT Varanasi19 Dec 2025AY 2016-2017

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2016-17 Town Educational Society V. Ito Ballia, Ward-2(4) Murli Manohar Town Pg Shashtri Park, Bhrighu College, Ballia, Uttar Pradesh- Ashram, Ballia-277001. 277001. Tan/Pan:Aadat7633C (Appellant) (Respondent) Appellant By: Shri Praveen Godbole, Ca Respondent By: Shri G. P. Singh, Sr. Dr Date Of Hearing: 11 12 2025 Date Of Pronouncement: 19 12 2025 O R D E R

For Appellant: Shri Praveen Godbole, CAFor Respondent: Shri G. P. Singh, Sr. DR
Section 10Section 148Section 69A

saving bank account, maintained with Punjab National Bank. Therefore, after obtaining the requisite approval of the Competent Authority, a notice under section 148 of the Income-tax Act, 1961 Page 3 of 6 (“Act” for short) was issued to the assessee by AO. However, the assessee failed to file

Venkata Prasad Pulipati, Amaravathi vs. Income-Tax Officer, Ward-2(1), Guntur

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 612/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.612/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Venkata Prasad Pulipati, Vs. Income Tax Officer, Amaravathi. Ward-2(1), Pan: Asapp8796L Guntur. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri I. Kama Sastry, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 30Section 69

property to the tune of Rs.29,63,200/-; and (iii) had sold an immovable property of Rs.4,10,000/-, reopened the case vide notice under section 148 of the Act, dated 30/06/2021. Thereafter, the AO, based on the judgment of the Hon’ble Supreme Court in the case ... Ashish Agarwal (2022) SCC Online SC 543, dated 04/05/2022, issued notice under section 148 of the Act, dated 27/07/2022. 3. Thereafter, the AO vide his order under section 30/05/2023 after making certain additions, viz., (i) short term capital gains (STCG) on sale of property: Rs.11,55,505/-; (ii) disallowance

Chandanam Sangaih & Son, Narsaraopeta vs. Income-Tax Officer, Ward-1, Narsaraopeta

In the result, the appeal by the assessee is allowed

ITA 567/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2017-18

Bench: Shri Sandeep Singh Karhail, Hon’Ble & Shri Omkareshwar Chidara, Hon’Bleआयकर अपील सं./I.T.A. No. 567/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2017-18) Chandanam Sangaih & Son V. Income Tax Officer – Ward - 1 7-159/47, Innaiah Gari Building Income Tax Office, 12-9-22/A Vinukonda Road Prakashnagar, Narsaraopeta Narasaraopeta, Guntur – 522601 Guntur – 522601 Andhra Pradesh Andhra Pradesh [Pan: Aalfc8018M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(2)Section 147Section 148Section 250

passed without issuing a notice under section 143(2) even though the assessee has filed a return of income in response to notice under section 148 dated 29.03.2021. 2. The notice under section 148 dated 29.03.2021 is invalid and bad in law as it is issued under the law existing ... credit to the taxes of Rs.57,486 and Interest of Rs.67,761 paid along with the return of income filed in response to notice under section 148 6. All the above grounds of appeal are mutually exclusive and without prejudice to one another. 7. The appellant craves leave

Vikram Brahmendra Satyajit Mulpuri, Krishna Dist vs. Income Tax Officer, Ward-3(1), Vijayawada

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 534/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2020-21

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.534/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Vikram Brahmendra Satyajit Vs. Income Tax Officer, Mulpuri, Ward-3(1), Krishna District. Vijayawada. Pan: Aonpm1893G (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri C. Subrahmanyam, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm:

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 148ASection 250Section 69A

return of income, initiated proceedings under section 148A of the Act. Thereafter, 3 Vikram Brahmendra Satyajit Mulpuri vs. ITO the AO issued notice under section 148 of the Act, dated 23/03/2024. In compliance, the assessee filed his return of income in response to the notice under section 148 ... Representative (for short, “Ld. AR”) for the assessee, submitted that both the impugned order passed under Section 148A(d) of the Act, and Notice under Section 148 of the Act, dated 22/03/2024 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions

Vulli Radhakrishna, Tuni vs. Income Tax Officer, Ward-1, Tuni

ITA 359/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.359/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Vulli Radhakrishna, Vs. Income Tax Officer, Tuni. Ward-1, Pan: Aegpv1751H Tuni. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 17/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short “A.O.”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short “The Act”) Dated 26/03/2022 For Assessment Year (Ay) 2015-16. 2 Vulli Radhakrishna Vs. Ito

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 151ASection 69A

recognized stock exchange: Rs.3,76,565/-; and (v) sale of equity shares: Rs.1,68,662/-, initiated proceedings under section 147 of the Act. Notice under section 148 of the Act was issued by the AO. In compliance, the assessee filed his return of income declaring an income

Shakira Khatoon (Wife&Lh)Late Rafeeq Ahmad Ansari, Sitapur vs. Dy.CIT, Sitapur

In the result, all the three appeals of the Assessee stand partly allowed for statistical purposes

ITA 63/LKW/2024[2016-17]Status: DisposedITAT Lucknow19 Dec 2025AY 2016-17

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Shri K. R. Rastogi, C.A and ShriFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 115BSection 139Section 144BSection 147Section 148Section 271(1)(c)Section 69A

hereinafter called “the Act’) were ITA Nos.62 & 63/LKW/2024 and ITA No.359/LKW/2023 Page 3 of 16 initiated against the assessee after issuing notice under section 148 of the Act to the assessee. In response to the notice under section 148 of the Act, the assessee filed the return of income

Shakira Khatoon( Wife&L/H)Late Rafeeq Ahmad Ansari, Sitapur vs. DCIT, Sitapur

In the result, all the three appeals of the Assessee stand partly allowed for statistical purposes

ITA 62/LKW/2024[2015-16]Status: DisposedITAT Lucknow19 Dec 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Shri K. R. Rastogi, C.A and ShriFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 115BSection 139Section 144BSection 147Section 148Section 271(1)(c)Section 69A

hereinafter called “the Act’) were ITA Nos.62 & 63/LKW/2024 and ITA No.359/LKW/2023 Page 3 of 16 initiated against the assessee after issuing notice under section 148 of the Act to the assessee. In response to the notice under section 148 of the Act, the assessee filed the return of income

Shkira Khatoon W/O Late Rafeeq Ahmad Ansari, Sitapur vs. DCIT, Sitapur

In the result, all the three appeals of the Assessee stand partly allowed for statistical purposes

ITA 359/LKW/2023[2017-18]Status: DisposedITAT Lucknow19 Dec 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Shri K. R. Rastogi, C.A and ShriFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 115BSection 139Section 144BSection 147Section 148Section 271(1)(c)Section 69A

hereinafter called “the Act’) were ITA Nos.62 & 63/LKW/2024 and ITA No.359/LKW/2023 Page 3 of 16 initiated against the assessee after issuing notice under section 148 of the Act to the assessee. In response to the notice under section 148 of the Act, the assessee filed the return of income

Ankitjain, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

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

ITA 913/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, CA
Section 115BSection 147Section 148Section 148ASection 292CSection 69

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

Sanjeev Kumar Nalam, Hyderabad vs. ITO, Ward-1, Nirmal

In the result, the appeal of the assessee is allowed

ITA 669/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Dec 2025AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.669/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Sanjeev Kumar Nalam Vs. Income Tax Officer Hyderabad Ward – 1 Pan:Avdpn0497L Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Waseem UR Rehman, Sr.DR
Section 147Section 148Section 148ASection 149(1)Section 151Section 153

Section 147 for the assessment year 2017-18. At the time of filing the appeal, certain important grounds relating to the issue of notice under Section 148 were not raised due to oversight. 2. The appellant submits that the notice issued under Section 148 dated 30/06/2021 is invalid ... Officer did not pass an order under Section 148A(d) and did not serve any such order on the appellant before issuing the notice under Section 148. Hence, the notice itself is bad in law. 3. The appellant further submits that the notice issued under Section 148 dated

Malireddi Srinath, Hyderabad vs. ITO, Ward-2(1), Hdyerabad, Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 1721/HYD/2025[2015-16]Status: DisposedITAT Hyderabad19 Dec 2025AY 2015-16

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 142(1)Section 144Section 144BSection 147Section 148Section 249(2)Section 249(3)Section 69A

accordingly proceedings under Section 147 of the Income-tax Act, 1961 were initiated for the Assessment Year 2015-16 by issue of notice under Section 148 of the Act, dated 29.04.2022. An intimation dated 15.12.2022 was issued regarding the completion of assessment proceedings in accordance with Section 144B

Bandaru Chandra Sekhar, Kadapa vs. ITO, Ward-1, Proddatur

In the result, appeal of the Assessee is allowed

ITA 1716/HYD/2025[2019-20]Status: HeardITAT Hyderabad19 Dec 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1716/Hyd/2025 Assessment Year 2019-2020 Bandaru Chandra The Income Tax Officer, Sekhar, Ward-1, Proddutur. Jammalamadugu Po & Vs. Pin – 516 350. Taluka, Kadapa Dist. Andhra Pradesh. Pin – 516 434. Pan Aozpb5357G (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca K A Sai Prasad राज" व "ारा /Revenue By: Ms Kritika Jaiswal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 17.12.2025 घोषणा की तारीख/Pronouncement: 19.12.2025 आदेश/Order

For Appellant: CA K A Sai PrasadFor Respondent: MS Kritika Jaiswal, Sr. AR
Section 147Section 148

head "Income from Other sources". 4. The Leamed First Appellate Authority erred in not considering the contention of the appellant that issuance of notice under section 148 by the local jurisdictional assessing officer is not legally valid and hence all further proceedings are equally bad in law. 5. The Appellant