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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

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

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

ITA 274/GTY/2025[2016-17]Status: DisposedITAT Guwahati11 Dec 2025AY 2016-17

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

Deputy Commissioner of Income Tax, Central Circle, Sambalpur vs. Smt. Indrani Patnaik, Rourkela

Appeals of the Revenue are dismissed

ITA 182/CTK/2020[2010-11]Status: DisposedITAT Cuttack11 Dec 2025AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri S.C. Bhadra, ARFor Respondent: Shri Ashim Kumar Chakraborty, DR
Section 143(2)Section 147Section 148Section 271(1)(c)Section 37

report. It must make its own assessment of facts before any action is initiated. In the present case, since it is a reopening notice under Section 148, it may not be necessary to give any pre- notice opportunity of hearing or producing of evidence to the affected parties. The notice ... however, imperative that the Assessing Officer must apply his own mind and make his own assessment of facts before he issues any notice under Section 148. 16. In the present case, as we have noted above, the only primary fact which was available in public domain and which is made

Deputy Commissioner of Income Tax, Central Circle, Sambalpur vs. Smt. Indrani Patnaik, Rourkela

Appeals of the Revenue are dismissed

ITA 181/CTK/2020[2010-11]Status: DisposedITAT Cuttack11 Dec 2025AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri S.C. Bhadra, ARFor Respondent: Shri Ashim Kumar Chakraborty, DR
Section 143(2)Section 147Section 148Section 271(1)(c)Section 37

report. It must make its own assessment of facts before any action is initiated. In the present case, since it is a reopening notice under Section 148, it may not be necessary to give any pre- notice opportunity of hearing or producing of evidence to the affected parties. The notice ... however, imperative that the Assessing Officer must apply his own mind and make his own assessment of facts before he issues any notice under Section 148. 16. In the present case, as we have noted above, the only primary fact which was available in public domain and which is made

Deputy Commissioner of Income Tax, Cental Circle, Sambalpur vs. Smt. Indrani Patnaik, Rourkela

Appeals of the Revenue are dismissed

ITA 180/CTK/2020[209-10]Status: DisposedITAT Cuttack11 Dec 2025

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri S.C. Bhadra, ARFor Respondent: Shri Ashim Kumar Chakraborty, DR
Section 143(2)Section 147Section 148Section 271(1)(c)Section 37

report. It must make its own assessment of facts before any action is initiated. In the present case, since it is a reopening notice under Section 148, it may not be necessary to give any pre- notice opportunity of hearing or producing of evidence to the affected parties. The notice ... however, imperative that the Assessing Officer must apply his own mind and make his own assessment of facts before he issues any notice under Section 148. 16. In the present case, as we have noted above, the only primary fact which was available in public domain and which is made

Deputy Commissioner of Income Tax, Cental Circle, Sambalpur vs. Smt. Indrani Patnaik, Rourkela

Appeals of the Revenue are dismissed

ITA 179/CTK/2020[2009-10]Status: DisposedITAT Cuttack11 Dec 2025AY 2009-10

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri S.C. Bhadra, ARFor Respondent: Shri Ashim Kumar Chakraborty, DR
Section 143(2)Section 147Section 148Section 271(1)(c)Section 37

report. It must make its own assessment of facts before any action is initiated. In the present case, since it is a reopening notice under Section 148, it may not be necessary to give any pre- notice opportunity of hearing or producing of evidence to the affected parties. The notice ... however, imperative that the Assessing Officer must apply his own mind and make his own assessment of facts before he issues any notice under Section 148. 16. In the present case, as we have noted above, the only primary fact which was available in public domain and which is made

Shri Pragjibhai Parsotambhai Tala, Rajkot vs. The ITO Ward-1 (1) (5), Rajkot

In the result, the assessee’s appeal is partly allowed, in above terms

ITA 271/RJT/2023[2007-08]Status: HeardITAT Rajkot11 Dec 2025AY 2007-08

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.271/Rjt/2023 "नधा"रणवष" / Assessment Year: (2007-08) (Hybrid Hearing) Shri Pragjibhai Parsotambhai Tala Vs. The Income-Tax Office, Ward- Maruti, Nr. Sitaram Chhatralaya, 1- 1(1)(5), Rajkot Harinagar, Aayakar Bhavan, Racecourse Rajkot-360001 Ring Road, Rajkot-360001 Gujarat Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaopt1813C (Appellant) (Respondent) Appellant By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 09 / 12 /2025 Date Of Pronouncement : 11 / 12 /2025

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 250

operative Bank of Rajkot Ltd. the AO for the purpose of verification, re-opened the case and issued notice under section 148 of the Act dated 14.032014 Pragjibhai Parsotambhai Trada and the appellant vide letter dated 09 02.2015 submitted to treat the return of income filed under section

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT(Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as

ITA 350/LKW/2025[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 40A(3)Section 69

APPEAL No. ITA-396/L/25 PAPER BOOK in Rakesh Kumar Pandey A.Y. 2016-17 (PAN — ATIPP6520B) INDEX Settee Particulars Copy of Notice under section 148 of the Income Tax Act, 1961 dated 17.03.2023 alongwith intimation letter dated 24.03.2023. Copy of reply namely “Reply —A” dated 05.09.2023 Copy of notice

M/S. Urban Nirman LLP, Kolkata vs. ITO, Ward 12(1), Kolkta

In the result, the appeal of the assessee is allowed

ITA 1730/KOL/2025[2013-2014]Status: DisposedITAT Kolkata11 Dec 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 148

that the failure by the AO to issue a notice to the Assessee under Section 143(2) of the Act, pursuant to a notice under Section 148 of the Act, is fatal to the order of re-assessment. Therefore, we respectfully following the decision of the Hon'ble Delhi High

Shri Dinesh Kumar Sanghai, Mumbai vs. DCIT, Cir-23(3), Mumbai

ITA 6346/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Dec 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

Section 147Section 148Section 149Section 151Section 153CSection 69

original return of income for the relevant year was filed by the assessee on 10.10.2016 declaring income of Rs.2,44,40,560/-. Notice under section 148 of the Act was issued on 28.07.2022, in response to which the return was filed by the assessee on 16.08.2022 declaring the same income ... before us, which is under consideration. 5. At the outset, the ld. AR on behalf of the assessee submitted that the issuance of notice under section 148 in the present matter itself is not in accordance with the mandate law and therefore the assessment completed based on such invalid notice

Gattula Lakshmi Madhavi, Visakhapatnam vs. Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, the appeal filed by the assessee in ITA

ITA 387/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

arrived at the balance tax liability of Rs. 2,89,080/-. Gattula Lakshmi Madhavi vs. ACIT 5. Thereafter, the assessee, in response to notice under section 148 of the Act, dated 30/03/2022, had filed her return of income for the year under consideration, i.e., AY 2018-19, on 09/05/2022, disclosing ... assessment passed by him under section 147 of the Act, dated 27/03/2023. Elaborating on his contention, the Ld. AR submitted that as the notice under section 148 of the Act, dated 30/03/2022 was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO), therefore, the assumption

Gattula Lakshmi Madhavi, Visakhapatnam vs. Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, the appeal filed by the assessee in ITA

ITA 386/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

arrived at the balance tax liability of Rs. 2,89,080/-. Gattula Lakshmi Madhavi vs. ACIT 5. Thereafter, the assessee, in response to notice under section 148 of the Act, dated 30/03/2022, had filed her return of income for the year under consideration, i.e., AY 2018-19, on 09/05/2022, disclosing ... assessment passed by him under section 147 of the Act, dated 27/03/2023. Elaborating on his contention, the Ld. AR submitted that as the notice under section 148 of the Act, dated 30/03/2022 was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO), therefore, the assumption

Gattula Lakshmi Madhavi, Visakhapatnam vs. Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, the appeal filed by the assessee in ITA

ITA 385/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.385, 386 & 387/Viz/2025 ("नधा"रण वष"/Assessment Year: 2018-19) Gattula Lakshmi Madhavi, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Pan: Agfpg8929H Central Circle-1, Visakhapatnam. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 15/10/2025 Hearing: घोषणा क" तार"ख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per Ravish Sood, Jm: The Captioned Appeals Filed By The Assessee Are Against The Respective Orders Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 21/03/2025, 24/03/2025 & 16/04/2025, Which In Turn Arises From The Respective Orders Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 Of The Income Gattula Lakshmi Madhavi Vs. Acit Tax Act, 1961 (For Short, "The Act”), Dated 27/03/2023; Under Section 271Aac(1) Of The Act, Dated 21/08/2023; & Under Section 270A Of The Act, Dated 21/08/2023 For Assessment Year 2018-19. As The Facts Involved In The Captioned Appeals Are Inextricably Interwoven, Therefore, The Same Are Being Taken Up & Disposed Of Vide A Consolidated Order.

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 147Section 148Section 148ASection 151ASection 270ASection 271ASection 69

arrived at the balance tax liability of Rs. 2,89,080/-. Gattula Lakshmi Madhavi vs. ACIT 5. Thereafter, the assessee, in response to notice under section 148 of the Act, dated 30/03/2022, had filed her return of income for the year under consideration, i.e., AY 2018-19, on 09/05/2022, disclosing ... assessment passed by him under section 147 of the Act, dated 27/03/2023. Elaborating on his contention, the Ld. AR submitted that as the notice under section 148 of the Act, dated 30/03/2022 was issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO), therefore, the assumption

Deputy Commissioner of Income Tax, Circle 3(1), Visakhapatnam vs. Doddi Roopa, Visakhapatnam

In the result, the appeal filed by the revenue is dismissed in terms of our aforesaid observations

ITA 413/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam10 Dec 2025AY 2019-20

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.413/Viz/2024 (िनधा"रण वष"/Assessment Year: 2019-20) Deputy Commissioner Of Vs. Smt. Doddi Roopa, Income Tax, Visakhapatnam. Circle-3(1), Visakhapatnam. Pan: Atfpr7237N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement:

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri Badicala Yadagiri
Section 131Section 133(6)Section 147Section 148Section 148A

proceedings under section 147 of the Act. Thereafter, an order under section 148A(d) of the Act, dated 29/03/2023, was passed, and a notice under section 148 of the Act, dated 29/03/2023, was issued by the AO. 3. During the course of the assessment proceedings, the AO for verifying ... purchases of Rs. 4,99,65,247/-, passed an order under section 148A(d) of the Act, dated 29/03/2023. Thereafter, the AO issued notice under section 148 of the Act, dated 29/03/2023, wherein the assessee was called upon to file her return of income in response to the same

Sukhdev Raj, Sirsa vs. Income Tax Officer, Sirsa

In the result, the appeal of the assessee is dismissed

ITA 632/CHANDI/2025[2013-2014]Status: DisposedITAT Chandigarh10 Dec 2025AY 2013-2014

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

For Appellant: Shri Lalit Mohan, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 10(37)Section 147Section 234ASection 234BSection 253Section 28Section 56(2)(viii)Section 57

offered for taxation in the ITR. Consequently, the case was reopened under Section 147 of the Income-tax Act, 1961, and a notice under Section 148 was issued on 24.04.2020. The Assessee subsequently furnished a return declaring the same income and arguing that the interest received under Section

Dhananjay Tradelink Pvt. Ltd., Ahmedabad vs. The ITO, Ward-1(1)(3), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 582/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Dec 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kambledhananjay Tradelink Pvt. Ltd., Income-Tax Officer, Vs. 505, Padshani Pole, Kalupur, Ward-1(1)(3), Ahmedabad-380001 Ahmedabad [Pan : Aadcd 8007 A] (Appellant) .. (Respondent) Appellant By : Shri S.N. Divetia, Ar Respondent By: Shri Rignesh Das, Cit-Dr Date Of Hearing 08.10.2025 Date Of Pronouncement 10.12.2025

For Appellant: Shri S.N. Divetia, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 143(3)Section 147Section 148Section 148ASection 250Section 68Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA R. KAMBLE, JUDICIAL

Dileep Kumar Sakamuri Chenchu Venkata, Srikalahasti vs. Income-Tax Officer, Ward-1(3), Tirupati

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

ITA 1615/HYD/2025[AY 2015-16]Status: DisposedITAT Hyderabad10 Dec 2025

Bench: Us:

Section 147Section 148Section 148ASection 234CSection 23BSection 250Section 69A

facts and circumstances of the case the Order under Section 147 rws 144 rws 144B of the Actis bad in law as the Notice under section 148 has been issued beyond the period of limitation prescribed under the Act 6. That on the facts and circumstances of the case ... Order under Section 147 rws 144 rws 144B of the Actis bad in law as the Notice under section 148 has been issued by Jurisdictional Assessing Officer and not Faceless Assessing Officer 7. The Appellant craves leave to add, amend, alter, vary and / or withdraw any or all the above

Satavahana University, Karimnagar vs. Income Tax Officer, Ward-2, Karimnagar

ITA 1526/HYD/2025[2019-2020]Status: DisposedITAT Hyderabad10 Dec 2025AY 2019-2020

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1524/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1525/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1526/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: Satavahana University Vs. Ito आदेश / Order

For Appellant: Shri E. Phalguna Kumar, CAFor Respondent: Dr. Narendra Kumar Naik
Section 10Section 10(230)Section 115BSection 139Section 147Section 148Section 148ASection 151ASection 250Section 69A

reopened its case and passed an order under clause (d) of section 148A of the Act on 28/03/2023. Thereafter, the AO issued notice under section 148 of the Act, dated 30/03/2023. In compliance, the assessee filed its return of income for AY 2016-17y on 26/05/2023, declaring its income ... passing order under clause (d) of section 148A of the income tax Act,1961 on 28.3.2023 and a notice under section 148 of the income tax Act, 1961 was also issued on 30.3.2023. During the assessment proceedings, the appellant has filed its return of income u/s 148

Satavahana University, Karimnagar vs. Income Tax Officer, Ward-2, Karimnagar

ITA 1525/HYD/2025[2018-2019]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-2019

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1524/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1525/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1526/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: Satavahana University Vs. Ito आदेश / Order

For Appellant: Shri E. Phalguna Kumar, CAFor Respondent: Dr. Narendra Kumar Naik
Section 10Section 10(230)Section 115BSection 139Section 147Section 148Section 148ASection 151ASection 250Section 69A

reopened its case and passed an order under clause (d) of section 148A of the Act on 28/03/2023. Thereafter, the AO issued notice under section 148 of the Act, dated 30/03/2023. In compliance, the assessee filed its return of income for AY 2016-17y on 26/05/2023, declaring its income ... passing order under clause (d) of section 148A of the income tax Act,1961 on 28.3.2023 and a notice under section 148 of the income tax Act, 1961 was also issued on 30.3.2023. During the assessment proceedings, the appellant has filed its return of income u/s 148

Satavahana University, Karimnagar vs. Income Tax Officer, Ward-2, Karimnagar

ITA 1524/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad10 Dec 2025AY 2016-2017

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1524/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1525/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr आ.अपी.सं /Ita No.1526/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2019-20) Satavahana University, Vs. Income Tax Officer, Karimnagar. Ward-2, Karimnagar. Pan: Aaajs4101N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri E. Phalguna Kumar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: Satavahana University Vs. Ito आदेश / Order

For Appellant: Shri E. Phalguna Kumar, CAFor Respondent: Dr. Narendra Kumar Naik
Section 10Section 10(230)Section 115BSection 139Section 147Section 148Section 148ASection 151ASection 250Section 69A

reopened its case and passed an order under clause (d) of section 148A of the Act on 28/03/2023. Thereafter, the AO issued notice under section 148 of the Act, dated 30/03/2023. In compliance, the assessee filed its return of income for AY 2016-17y on 26/05/2023, declaring its income ... passing order under clause (d) of section 148A of the income tax Act,1961 on 28.3.2023 and a notice under section 148 of the income tax Act, 1961 was also issued on 30.3.2023. During the assessment proceedings, the appellant has filed its return of income u/s 148

Venkata Rama Krishnam Raju Chintalapati, Hyderabad vs. DCIT., Circle 8(1), Hyderabad

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

ITA 144/HYD/2025[2019-20]Status: DisposedITAT Hyderabad10 Dec 2025AY 2019-20

Bench: Us.

Section 144Section 147Section 148Section 148ASection 151ASection 68

based on the financial transactions reported, including unexplained credit of Rs. 2,54,23,303/-, initiated proceedings under section 148A of the Act. Notice under section 148 of the Act, dated 31.03.2023, was issued by the AO. In response, the assessee filed his return of income, declaring an income ... Assessment of Income Escaping Assessment Scheme, 2022", it is only the “Faceless Assessing Officer” (FAO) who can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing Officer” (JAO), and the assessments are statutorily required to be as per the prescribed faceless mechanism provided under