“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

Rajendra Sahu, Katni vs. Income Tax Officer-1, Katni

ITA 163/JAB/2023[2014-15]Status: DisposedITAT Jabalpur12 Dec 2025AY 2014-15

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rahul Bardia, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR 1

Section 131Section 147Section 148Section 69

Commissioner of Central Excise 281 CTR (SC) 241 The assessee also submitted that the AO had erred in law in issuing the notice under section 148 without proper application of mind. The assessee invited attention to the appeal filed by Sh. Amarnath Pyasi ... which had been passed by the same AO who had recorded the reasons for issue of notice under section 148 in the case of the assessee. It was submitted that the same AO had assessed the entire income from investment in the purchase of the property

Anwar Husain Mehboob Shaikh, Jalgaon vs. Income Tax Officer, Jalgaon

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

ITA 2561/PUN/2025[2018-2019]Status: DisposedITAT Pune12 Dec 2025AY 2018-2019

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2561/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Anwar Husain Mehboob V The Income Tax Officer, Shaikh, S Jalgaon. H. No.K 258/I Railway North Area, Bhusawal, Jalgaon – 425201. Pan: Bodps9742F Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Sandeep Sathe - Dr Date Of Hearing 10/12/2025 Date Of Pronouncement 12/12/2025 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.2018-19 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 31.01.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144BSection 147Section 148Section 151ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

r.w.s 144 of the Act, dated 31.01.2024. The Assessee has raised the following grounds of appeal : ITA No.2561/PUN/2025 [A] “1. That the notice under section 148 of the Act for the reassessment of income for the AY 2018-19 was wrongly issued by the Jurisdictional Assessing Officer instead of Faceless ... Assessing Officer. 2. That the Jurisdictional AO has excess is authority by issuing notice under section 148 of the Act. 3. That the notice issued under section 148 violates the section 151A and 1448 of the Act and is bad in law and hence the complete re- assessment proceedings need

Swamini Mahila Gramin Bigarsheti Sahkari Patsanstha Maryadit, Pune vs. ITO Ward 12(3), Pune

In the result, appeal of the assessee is partly allowed

ITA 2533/PUN/2025[2015-2016]Status: DisposedITAT Pune12 Dec 2025AY 2015-2016

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2533/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Swamini Mahila Gramin V The Income Tax Officer, Bigarsheti Sahakari Patsanstha S. Ward-12(3), Pune. Maryadit, Survey No.272, Sainagar Gourav Bunglow, Lohagaon, Near Uttareshwar Mandir, Pune – 411047. Pan: Aakas1168G Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajendra Agiwal Revenue By Smt Indira R. Adakil-Addl.Cit(Dr) Date Of Hearing 02/12/2025 Date Of Pronouncement 12/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is 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 A.Y.2015-16, Dated 19.08.2025 Emanating From Assessment Order 147 R.W.S 144B Of The

Section 133(6)Section 148Section 149Section 151ASection 250Section 282Section 69A

income u/s.139(1) of the Act. Assessing Officer received information that Assessee had made cash deposits of Rs.76,10,070/- during the year. Notice under section 148 dated 06.04.2022 was issued for A.Y.2015-16 in the case of Assessee. Copy of the notice is at page no.80 of the paper book ... learned counsel for the parties. It is not in dispute that the present petition relates toA.Y.2015-16. Further, it is also undisputed that the notice under Section 148 has been issued on 5th April 2022which is at page 52 of the paperbook. Once these are the facts, paragraphs

Chandini Duvvuri, Hyderabad vs. ITO (Int Taxn)-1, Hyderabad

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

ITA 1432/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Dec 2025AY 2015-16

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

Section 147Section 148Section 148ASection 151A

said deposits and interest receipts were not explained before the Department. Consequently, the A.O., after following due procedure prescribed under Section 148A, issued notice under Section 148 of the Act on 04.04.2022, with the prior approval of the competent authority. During the reassessment proceedings, several opportunities were provided through notices ... Tribunal. 10. The learned counsel for the assessee, submitted that, the Ld. CIT(A) erred in confirming the action of the JAO issuing notice under Section 148 of the Act, without having proper power to do so in view of the decision of the Hon'ble Telangana High Court

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1396/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

under section 148A(a) of the Act. Order under section 148A(d) of the Act was passed on 28/04/2022. Thereafter, the AO issued notice under section 148 of the Act, dated 28/04/2022. 4. Thereafter, the AO vide his order under section 147 r.w.s 144 r.w.s 144B of the Act, dated ... assessee as per section 282 r.w. Rule 127 of the Income Tax Rules, 1962. 9. The Ld.AR submitted that the AO had issued notice under section 148 of the Act, 28/04/2022 after obtaining the approval of the Principal Commissioner of Income Tax, Hyderabad-1 on 28/04/2022, vide Reference No.100000029497859. Elaborating

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1395/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

Padmalatha Vojjala, Secunderabad vs. ITO., Ward-10(1), Hyderabad

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

ITA 1240/HYD/2025[2019-2020]Status: DisposedITAT Hyderabad12 Dec 2025AY 2019-2020

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1240/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Smt. Padmalatha Vojjala Vs. Income Tax Officer Secunderabad Ward 10 (1) Pan:Cajps9715B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri D.V. Anjaneyulu, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 10/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri D.V. Anjaneyulu, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR

Section 139Section 143(2)Section 147Section 148Section 69A

Urban Bank Ltd. during the relevant previous year. Accordingly, the case of the assessee was reopened under section 147 of the Act and notice under section 148 of the Act was issued on 23.03.2023. The assessee initially did not file any return of income nor respond to statutory notices. Subsequently ... assessee filed a return of income in response to notice under section 148 of the Act declaring total income of Rs.80,410/-. During the assessment proceedings, notice under section 143(2) dated 26.02.2024 was issued by the Ld. AO. The Ld. AO called for details regarding the source

Selvaraj Arokia Sagaya Raj, Chennai vs. DCIT, Ncc-22(1), Chennai

In the result, the appeal of the assessee is allowed, and the stay application is dismissed as infructuous

ITA 3597/CHNY/2025[2018-19]Status: DisposedITAT Chennai12 Dec 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3597/Chny/2025 & S.A No.118/Chny/2025 िनधा%रण वष% /Assessment Year: 2018-19 Selvaraj Arokia Sagaya Raj, The Dy. Commissioner Of Income 6/9 Ff1, Soundariya Apartments, Vs. Tax, Voc 2Nd Main Road, Non Corporate Circle-22(1), Kodambakkam, Tambaram, Chennai. Chennai – 600 024. Pan: Aeypa 8464Q

For Appellant: Mr. N.V.Krishnan, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 147Section 148Section 148ASection 250

Court in the case of ITA No3597/Chny/2025 & SA No.118/Chny/2025 Selvaraj Arokia Sagaya Raj :- 3 -: Bevinakuppe Ningegowda vs ITO in WP No.16325 of 2025, notice under section 148 of the Act and assessment order passed pursuant to the said notice are liable to be treated ... herein marked as Annexure - A. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under section 148 of the Act dated 27/04/2022 bearing DIN No. ITBA/AST/S/148_1/2022- 23/1042880981(1) issued by the Respondent No.1 for the assessment year 2018-19 herein

Sri Krisha Traders, Sivagangai vs. DCIT, Non Corporate Circle-1, Madurai

In the result, the appeal of the assessee is allowed

ITA 2223/CHNY/2025[2017-18]Status: DisposedITAT Chennai12 Dec 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2223/Chny/2025 िनधा%रण वष% /Assessment Year: 2017-18

For Appellant: Mr. N. Vijay Kumar, C.A *+For Respondent: Ms. Babitha, JCIT

Section 139(1)Section 147Section 148Section 250Section 40A(3)

course of reassessment proceedings, can be brought to tax, only, if the escaped income, which caused, in the first instance, the issuance of notice under Section 148 of the Act, is assessed to tax. 22. Explanation 3, to my mind, supports this approach, which emerges upon a plain reading ... other income which has escaped assessment and which, comes to his notice during the course of the proceedings. However, if after issuing a notice under section 148, he accepted the contention of the assessee and holds that the income which he has initially formed a reason to believe had escaped

Ranjeet Kumar Yadav, Chennai vs. ITO, Ncw-6(1), Chennai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2215/CHNY/2025[2018-19]Status: DisposedITAT Chennai12 Dec 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. Nos.2214 & 2215/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 Ranjeet Kumar Yadav, Vs. The Income Tax Officer, 87/5, Gnt Road, Balaji Nagar, Non Corporate Ward 6(1), Padiyanallur, Chennai 600 052. Chennai 600 006. [Pan:Atjpr9158E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri M. Karunakaran, Advocate ""थ" की ओर से/Respondent By : Ms. Babitha, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.12.2025 घोषणा की तारीख /Date Of Pronouncement : 12.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Dated 28.12.2023 23.11.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2017-18 & 2018-19 Respectively.

For Appellant: Shri M. Karunakaran, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 139Section 142(1)Section 147Section 148Section 69

purchased a motor vehicle for ₹.1,53,46,500/- during the AY under consideration. Accordingly, the Assessing Officer issued notice under section 148 of the Income Tax Act, 1961 [“Act” in short] dated 30.03.2021 for furnishing return of income. Thereafter, notices under section 142(1) of the Act were issued ... note that the assessee has not filed return of income under section 139 of the Act or in response to the notice under section 148 of the Act dated 30.03.2021. Further, the assessee has not at all furnished any details in response to the notices issued under section

Ranjeet Kumar Yadav, Chennai vs. ITO, Ncw-6(1), Chennai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 2214/CHNY/2025[2017-18]Status: DisposedITAT Chennai12 Dec 2025AY 2017-18

For Appellant: Shri M. Karunakaran, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 139Section 142(1)Section 147Section 148Section 69

ACIT Circle-20(1), Mumbai vs. Jayesh Umakant Manania, Mumbai

Accordingly, the appeal filed by the Revenue stands dismissed

ITA 6588/MUM/2025[2012-13]Status: DisposedITAT Mumbai12 Dec 2025AY 2012-13

Bench: Smt. Beena Pillai & Shri Makarand Vasant Mahadeokarjayesh Umakant Acit Circle-20(1) Manania Room No. 305, 3Rd Floor, 131-6, Mani Bhuvan Piramal Chambers, Parel, Vs. Jain Society, Sion Mumbai-400 012 East, Mumbai-400022 Pan/Gir No. Aacpm0547J (Applicant) (Respondent) Revenue By Ms. Kavitha Kaushik, Ld. Dr Assessee By Shri Suchek Anchaliya, Ld. Ar Date Of Hearing 10.12.2025 Date Of Pronouncement 12.12.2025

Section 132Section 133ASection 143(1)Section 143(3)Section 147Section 148Section 153CSection 69Section 69A

basis of the aforesaid material, the Assessing Officer recorded reasons to believe that income chargeable to tax had escaped assessment and issued notice under section 148 on 30.03.2018. 4. During reassessment proceedings, the Assessing Officer confronted the assessee with the seized materials and the mobile phone data retrieved from

Techno Residency Co Operative Housing Society Limited, Mumbai vs. Income Tax Officer Ward 20(2)(1), Mumbai

Appeal is allowed

ITA 5742/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Dec 2025AY 2015-16

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

For Appellant: Shri Dharan Gandhi & Ms. Vinita NaraFor Respondent: Shri Hemanshu Joshi

Section 144BSection 147Section 148Section 234ASection 249Section 271(1)(b)Section 69ASection 80P

submitted that the Assessment Order passed by the Assessing Officer under Section 147 of the Act was bad in law since the notice under Section 148 of the Act has been issued for the Assessment Year 2015-16 on 06/04/2022. Since the said notice has been issued after 01/04/2021 ... Regime as notice issued under Section 148A(b) of the New Regime and passed order under Section 148A(d) of the Act. Thereafter, notice under Section 148 of the New Regime was issued by the Assessing Officer Act between July and September, 2022. In the aforesaid background following issues came

Ramniwas Sharma, Delhi vs. DCIT Circle 2(1), Gaziabad

In the result, the appeal of the assessee is accordingly allowed as above terms for statistical purposes

ITA 5066/DEL/2025[2013-14]Status: DisposedITAT Delhi12 Dec 2025AY 2013-14

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

Section 144Section 147Section 148Section 151Section 250Section 69A

filed return of income for A.Y. 2013-14 and the case of appellant was reopened by the Assessing Officer by issuing notice under section 148 of the Act on 24th March, 2021 and subsequently, the AO completed the assessment and passed order under section 147 r.w.s. 144/144B

East End Apartments Cghs Ltd, Delhi vs. ITO, Ward 60(1), Delhi

In the result, the appeal of the assessee is accordingly allowed as above terms for statistical purposes

ITA 5054/DEL/2025[2015-16]Status: DisposedITAT Delhi12 Dec 2025AY 2015-16

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

Section 142(1)Section 144Section 148ASection 249(3)Section 250

Appeals)/National Faceless Appeal Centre (NFAC) has grievously erred in law and on facts, confirming the order and consequently the Notice under Section 148 of the Act. The same being without jurisdiction and in violation of the sections 147, 149, and 151 of the Act. 5. The CIT (Appeals)/National ... NFAC) has grievously erred in law and on facts, confirming the order treating the return filed by the appellant in response to the notice under section 148 of the Act as invalid, as the same has been duly e-verified. 10. The appellant seeks leave to consider

Income Tax Officer, Ward 46(1), New Delhi vs. Mam Raj Chunni Lal Exim, New Delhi

In the result the appeal of the Revenue is dismissed and the cross objection of the assessee is partly allowed

ITA 3573/DEL/2024[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2016-17 Income Tax Officer, Vs Mam Raj Chunni Lal Exim Ward- 46 (1) Shop No. 5183, Ground New Delhi Floor, Lahori Gate, Naya Bazar, Delhi -110006 Pan No.Aaxfm0533B (Appellant) (Respondent)

Section 133ASection 147Section 148Section 148ASection 149(1)Section 151Section 151A

make a scheme, by notification in the Official Gazette, for the purposes of assessment, reassessment or recomputation under section 147 or issuance of notice under section 148 35[or conducting of enquiries or issuance of show-cause notice or passing of order under section 148A] or sanction for issue ... notify a scheme for the purpose of 1. the purpose of assessment, reassessment or re-computation under Section 147; or 2. issuance of notice under Section 148; or 3. conducting of inquiry or issuance of show cause notice or passing of order under Section 148A; or 4. sanction for issuance

ACIT, Circle-2, Noida vs. Noida Special Economic Zone Authority, Noida

In the result, the assessing officer is directed to allow both the disallowances

ITA 6732/DEL/2018[2012-13]Status: DisposedITAT Delhi12 Dec 2025AY 2012-13

Bench: Shripawan Singhand Shribrajesh Kumar Singhआ.अ.सं/.I.T.A No.6540/Del/2018 िनधा"रणवष"/Assessment Year:2010-11 (Physical Hearing) Noida Special Economic Zone Authority, बनाम Dcit, Phase-Ii, Dadri Road, Noida, Circle-2, Vs. Uttar Pradesh. Aayakar Bhawan, 2D, A-Block, Sector-24, Pan No.Aaaln0639A Noida, Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6541/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Noida Special Economic Zone Authority, बनाम Dcit,Circle-2, Phase-Ii, Dadri Road, Noida, Aayakar Bhawan, 2D, Vs. Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं/.I.T.A No.6732/Del/2018 िनधा"रणवष"/Assessment Year:2012-13 Acit, बनाम Noida Special Economic Zone Authority, Circle-2, Phase-Ii, Dadri Road, Noida, Vs. Aayakar Bhawan, 2D, Uttar Pradesh. A-Block, Sector-24, Noida, Uttar Pradesh. Pan No.Aaaln0639A अपीलाथ" Appellant ""यथ"/Respondent Assessee By Shri Ram Avtar Sharma, Ca & Shri Bhupesh Agarwal, Ca Revenue By Ms. Monika Singh, Cit-Dr सुनवाईक"तारीख/ Date Of Hearing: 26.11.2025 उ"ोषणाक"तारीख/Pronouncement On 12.12.2025 आदेश /O R D E R Per Pawan Singh:

Section 139(1)Section 139(4)Section 143(1)Section 147Section 148Section 154Section 34Section 80ASection 80I

dated 21.07.2016, directed the Assessing Officer to initiate reassessment proceedings under section 147. Pursuant to the direction of PCIT, the Assessing Officer issued notice under section 148 dated 07.03.2017. The assessee was provided the reasons recorded vide letter dated 25.03.2017. On supply of the reasons recorded, the assessee filed

Noida Special Economic Zone Authority, Noida vs. DCIT, Circle-2, Noida

In the result, the assessing officer is directed to allow both the disallowances

ITA 6541/DEL/2018[2012-13]Status: DisposedITAT Delhi12 Dec 2025AY 2012-13

Section 139(1)Section 139(4)Section 143(1)Section 147Section 148Section 154Section 34Section 80ASection 80I

Noida Special Economic Zone Authority, Noida vs. DCIT, Circle-2, Noida

In the result, the assessing officer is directed to allow both the disallowances

ITA 6540/DEL/2018[20101-11]Status: DisposedITAT Delhi12 Dec 2025

Section 139(1)Section 139(4)Section 143(1)Section 147Section 148Section 154Section 34Section 80ASection 80I

Mitchell Wankhar, Shillong vs. ITO W-2, Shillong

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

ITA 275/GTY/2025[2022-23]Status: DisposedITAT Guwahati11 Dec 2025AY 2022-23

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 10(26)Section 148Section 148ASection 250Section 271ASection 4Section 44ASection 69A

assessment was reopened under section ITA Nos.: 274 & 275/GTY/2025 Assessment Years: 2016-17 & 2022-23 Mitchell Wankhar. 147 of the Act by issuing notice under section 148 of the Act. The assessee filed the return of income in response to the notice issued and also filed other details