“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

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 143/HYD/2025[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: Us:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri Waseem UR Rehman

Section 147Section 148Section 148ASection 151

section (ii) of Section 151 of the Act, viz. Principal Chief Commissioner/Principal Director General/Chief Commissioner /Director General. The Ld. AR submitted that the notice under Section 148 of the Act, dated 18/04/2022, had been issued in the present case after obtaining the prior approval of the Principal Commissioner of Income ... accorded on 18.04.2022 vide reference No.100000029981043 (copy on record). 7. Carrying his contention further, the Ld. AR submitted that as the impugned notice under Section 148 of the Act, dated 18.04.2022 had been issued by the A.O. without obtaining the approval of the prescribed authority, therefore the said notice

Manikumari Samanchi, Zaheerabad vs. Income Tax Officer, Ward-1, Sangareddy

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

ITA 1345/HYD/2025[2016-17]Status: DisposedITAT Hyderabad10 Dec 2025AY 2016-17

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

Section 147Section 148Section 148ASection 14BSection 69A

cash deposits aggregating to Rs.2 lakhs or more with a banking company: Rs.29.45 lakhs, initiated proceedings under section 148A of the Act. Notice under section 148 of the Act, dated 22/04/2023, was issued by the ITO, Ward-1, Sangareddy, i.e., Jurisdictional Assessing Officer (JAO). 3. Thereafter, the AO vide ... 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

Manikumari Samanchi, Zaheerabad vs. Income Tax Officer, Ward-1, Sangareddy

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

ITA 1344/HYD/2025[2015-16]Status: DisposedITAT Hyderabad10 Dec 2025AY 2015-16

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

Section 147Section 148Section 148ASection 14BSection 69A

Aliveni Gurram, Karimnagar vs. ITO., Ward-2, Karimnagar

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

ITA 1297/HYD/2025[2017-18]Status: HeardITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1297/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Smt. Aliveni Gurram Vs. Income Tax Officer Karimnagar Ward – 2 Pan:Burpg4403M Karimnagar (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Chaitanya Kumar, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 04/12/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri T. Chaitanya Kumar, AdvocateFor Respondent: : Shri Waseem UR Rehman, Sr. DR

Section 133(6)Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 250(6)Section 69A

State Bank of Hyderabad. Accordingly, the Ld. AO initiated proceedings under section 147 of the Income Tax Act, 1961 (“the Act”) and issued notice under section 148 of the Act dated 30.03.2021. In response, the assessee filed her return of income on 30.05.2021 declaring a total income of Rs.83

Siva Sankara Reddy Tunga, Hyderabad vs. ITO., Ward - 14(1), Hyderabad

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

ITA 1060/HYD/2025[2016-17]Status: DisposedITAT Hyderabad10 Dec 2025AY 2016-17

Bench: Us:

Section 147Section 148Section 148ASection 69A

Thereafter, the AO passed an order under section 148A(d) of the Act, dated 25/03/2023. 4 Siva Sankara Reddy Tunga vs. ITO Notice under section 148 of the Act, dated 25/05/2023, was thereafter served upon the assessee. In compliance, the assessee filed his return of income ... sustained and is liable to be quashed on the said count itself. 9. Apart from that, the Ld. AR submitted that the notice under section 148 of the Act, dated 25/03/2023, had been issued by the Jurisdictional Assessing Officer (JAO), i.e., Income Tax Officer, Ward-14(1), Hyderabad, Page No.1

Income Tax Officer, Ward-1, Warangal vs. Shiva Kumar Thota, Warangal

In the result, the primary objection filed by the assessee vide his letter, dated 02/06/2025 is allowed while for the appeal filed by

ITA 996/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Dec 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.996/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Income Tax Officer, Vs. Shiva Kumar Thota, Ward-1, Warangal. Warangal. Pan: Aaopt4519M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By: Mrs. U. Mini Chandran, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 18/11/2025 घोषणा की तारीख/Date Of 10/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Revenue Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2024 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 26/05/2023 For The Assessment Year 2017-18. The Revenue Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Mrs. U. Mini Chandran

Section 147Section 148Section 148ASection 43BSection 68

Also, the revenue has raised an additional grounds of appeal, as under: “Notice u/s 148 issued on 29/07/2022, in respect of initial notice under section 148, dated 28/06/2021, and reply on 01/06/2022, is barred by limitation as per the ratio laid down by the Hon’ble Supreme Court ... fact that more than 3 vears lapsed from the end of the relevant A.Y. 2017-18 the approval for isuance of notice under section 148 granted on 29.07.2022 by Ld. Principal Commissioner of Income (PCIT-1), Hyderabad is bad in law, since the competent authority for granting such approval

Urmila Garg, Howrah vs. ITO, Ward 47(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1734/KOL/2025[2013-2014]Status: DisposedITAT Kolkata10 Dec 2025AY 2013-2014

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2013-14 Urmila Garg…………………………..………………….……….……….……Appellant Flat No.402, 138 Block-A, 4Th Floor, Gt Road, Howrah - 711102.. [Pan: Adapg1577B] Vs. Ito, Ward-47(1), Kolkata..…………...…………………….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 03, 2025 Date Of Pronouncing The Order : December 10, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 06.06.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 147Section 148Section 148ASection 250

statutory formalities under section 148A of the Act as prescribed by the Finance Act, 2021 which are applicable w.e.f 01.04.2021 before issuance of notices under section 148 of the Act. The ld. AR further states that the Assessing Officer though has noted down the date of issuance of Notice ... statutory formalities under section 148A of the Act as prescribed by the Finance Act, 2021 which are applicable w.e.f 01.04.2021 before issuance of notices under section 148 of the Act. We have gone through the order passed by the Hon’ble Calcutta High Court in the case of Marudhar Vintrade

Salil Sadanand Phadte, Mumbai vs. ITO Ward 42(3)(3), Mumbai

In the result, appeal of the assessee is treated as allowed for

ITA 4748/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Dec 2025AY 2013-14

Bench: Smt. Beena Pillai & Shri Makarand Vasant Mahadeokar

Section 133(6)Section 144BSection 147Section 148Section 201(1)Section 250Section 69A

failure of the assessee to file a return, the AO recorded reasons to believe that income had escaped assessment and issued a notice under section 148 on 22.07.2022, which was duly served. The assessee thereafter filed a return on 22.08.2022, declaring total income of Rs.19,11,780/- which included Rs.21

Dy. Commissioner, DCIT Central vs. Cable Corporation India Limited, Mumbai

In the result, grounds of appeal raised by Revenue are dismissed

ITA 5126/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Dec 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Dcit, Central Circle 2(2), Mumbai Cable Corporation Of India Limited, 4Th Floor, Laxmi Building, Room No. 806, Old Cgo Building Vs Pratistha Bhawan M.K. Road, 6, Shoorji Vallabhdas Ballard Estate, Mumbai – 400020. Mumbai-400001 (Pan:Aaac C2936 J) Appellant / Revenue Respondent / Assessee

Section 131Section 147Section 148Section 254(1)Section 37

also covered. Consequent upon search action and material gathered during the search action, the case of assessee was reopened under section 147. Notice under section 148 dated 31.03.2023 was served upon the assessee. In response to notice under section 148, the assessee filed return of income on 10.04.2023 declaring

Dy. Commissioner of Income Tax, Mumbai vs. Cci Projects Private Limited, Mumbai

In the result, grounds of appeal raised by Revenue are dismissed

ITA 5097/MUM/2024[2019]Status: DisposedITAT Mumbai10 Dec 2025

Section 131Section 147Section 148Section 254(1)Section 37

Dy. Commissioner of Income Tax, Pratistha Bhawan Mumbai vs. Cci Projects Pvt Ltd, Mumbai

In the result, grounds of appeal raised by Revenue are dismissed

ITA 5034/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Dec 2025AY 2014-15

Section 131Section 147Section 148Section 254(1)Section 37

Mohd Ayyub, Delhi vs. Income Tax Officer, Ward-28(1), Delhi

The appeal of the assessee is allowed

ITA 4882/DEL/2025[2015-16]Status: DisposedITAT Delhi10 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Naveen Chandramohd. Ayyub Vs. Ito, Ward – 28(1) C-15/1, Shaheen Bagh, Civic Centre, Abul Fazal, Enclave-Ii, Minto Road, Jamia Nagar Okhla, New Delhi – 110002 New Delhi – 110025 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Boxpa9409P Appellant .. Respondent

For Appellant: Ms. Meenal Goyal, CAFor Respondent: Sh. Om Prakash, Sr. DR

Section 147Section 148Section 148A

P a g e | 1 Mohd. Ayyub (AY: 2015-16) IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, DELHI BEFORE

Umar Daraj, Meerut vs. ITO Ward-1(2)(4), Meerut

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

ITA 3095/DEL/2025[2015-16]Status: DisposedITAT Delhi10 Dec 2025AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Yogesh Kumar U.S.Umar Daraj, Vs. Ito, Ward 1(2)(4), 153/1, Hapur Road, Meerut. Umar Nagar, Meerut – 250 001 (Uttar Pradesh). (Pan : Ainpd8766H) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Shri Dayainder Singh Sidhu, Citdr Date Of Hearing : 17.09.2025 Date Of Order : 10.12.2025 O R D E R Per S. Rifaur Rahman:

For Appellant: Shri Sumit Lal Chandani, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CITDR

Section 142(1)Section 143(3)Section 148Section 151Section 40A

original return of income on 20.09.2015 declaring total income of Rs.7,66,440/-. The case of the assessee was reopened by issue of notice under section 148 of the Income-tax Act, 1961 (for short ‘the Act’) dated 30.03.2021 after obtaining approval from the competent authorities. In response, assessee submitted ... initiated for AY 2015-16 is void ab initio, as the approval granted under Section 151 is both illegal and mechanically accorded. The notice under Section 148 was issued on 30.03.2021, i.e. prior to 01.04.2021, and therefore the governing law was the pre-Finance Act 2021 regime. In terms

Aakanksha Gupta, Delhi vs. ITO Ward 69(1), New Delhi, Delhi

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

ITA 2763/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Dec 2025AY 2017-18

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2763/Del/2025 िनधा"रणवष"/Assessment Year: 2017-18 बनाम Aakanksha Gupta, Income Tax Officer, C/O Ca Vaibhav Goel, Vs. Ward 69(1), 78, Navyug Market, 1St Floor, New Delhi. Ghazaibad, Uttar Pradesh. Pan No.Amhpg9430D अपीलाथ" Appellant ""यथ"/Respondent

Section 143(2)Section 144BSection 147Section 148Section 149Section 250Section 54

assessment from 6 years to 3 years, revenue, with a view to avail limitation prescribed under un-amended section 149, generated reassessment notices under section 148 dated 31-3-2021, but same were despatched on or after 1-4-2021 - Assessee challenged validity of notices issued under section 148 - Whether ... attached and triggering e-mail to assessee is performed by ITBA e- mail software system - Held, yes - Whether thus, mere generation of notice under section 148 on ITBA software cannot in fact or in law constitute issue of notice, it is only upon due despatch that notice can be said

Girish Lahori, Gandhidham vs. Income Tax Officer Ward-1 Gandhidham, Gandhidham

In the result this appeal was allowed, the order of the High Court was set aside and the

ITA 283/RJT/2025[2010-11]Status: DisposedITAT Rajkot09 Dec 2025AY 2010-11

Bench: Dr. Arjun Lal Saini, Accountnt Member & Shri Dinesh Mohan Sinha, Judicial Membr

Section 144Section 147Section 148Section 234ASection 271(1)(c)Section 69

delete any of the above grounds of appeals.” 3. The facts of the case which can be stated quite shortly are as follows: Notice under section 148 of the Act, was issued to the assessee, on 28.03.2017 after recording of reasons. As the assessee had not filed his return ... income in response to notice under section 148 of the Act, a letter was issued on 20.06.2017 to the assessee for filing of return of income. Since the assessee had not responded to the notice under section 148 of the Act or the letters issued thereafter, assessing officer framed

K.G.N.Enterprise, Veraval vs. Income Tax Officer, Veraval

In the result, appeal filed by the assessee is allowed

ITA 181/RJT/2025[2019-20]Status: DisposedITAT Rajkot09 Dec 2025AY 2019-20

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.181/Rjt/2025 िनधा"रण वष"/Assessment Year : 2019-20 K.G.N. Enterprise बनाम/ Income Tax Officer Al Iraki Bageraza Lucky Colony, Vs Ward – 4, Range 201, Junagarh, Ner Somnathtokish, Behind Amit Veraval Akela Clinic, Veraval, Gir Somnath, Gujarat - 362264 "ायीलेखासं./जीआइआरसं./Pan/Gir No.:Aatfk8798E (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri R. B. Shah, Ld. Ar राज"की ओर से / Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख /Date Of Hearing : 15/09/2025 घोषणा की तारीख /Date Of Pronouncement : 09/12/2025 आदेश/Order

For Appellant: Shri R. B. Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 139(1)Section 147Section 250

course of the proceedings though the reasons for such issue were not included in the notice; however, if after issuing a notice under section 148 of the Act, the assessing officer accepted the contention of the assessee and holds that the income which he has initially formed a reason

ACIT, Circle-2, Patna vs. Shree Nanak Ferro Alloys Pvt Ltd, Jamshedpur

In the result, the appeal of the Revenue is dismissed

ITA 249/PAT/2019[2013-14]Status: HeardITAT Patna09 Dec 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Shree Nanak Ferro Alloys Pvt. Ltd. Acit, Circle-2 Room No.205, 2Nd Floor, Avrtar Acit, Circle-2, Patna, Bihar Vs. Building, Bisturpur, Jamshedpur, Jharkhand (Appellant) (Respondent) Pan No. Aaics1706N Assessee By : S/Shri A.K. Rastogi Rakesh Kumar, Ar Revenue By : Shri Md Ah Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 09.12.2025

For Appellant: S/Shri A.K. RastogiFor Respondent: Shri MD AH Chowdhary, DR

Section 139Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

declaring the total income of ₹18,41,971/-. The case of the assessee was reopened under Section 147 of the Act by issuing notice under Section 148 of the Act on 04.11.2015, which was not complied with by the assessee. Again, reminder dated 08.12.2015 was given, which was complied with ... well as trading in goods. The case of the assessee was reopened by the AO under Section 147 of the Act by issuing notice under Section 148 of the Act on 04.11.2015, after the learned Assessing Officer received information from Director of Income Tax (I & CI) that appellant had received

Dy. Commissioner of Income Tax, Central Circle-3, Ludhiana vs. Raman Seth, Ludhiana

ITA 966/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh09 Dec 2025AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 148Section 69A

first as it involved a pure legal issue striking at the very root of the reassessment proceedings. The factual matrix indicated that a notice under section 148 had been issued on 27.03.2023 by the Jurisdictional Assessing Officer, as is evident from the assessment order itself as well as from ... amendments to sections 144B, 148 and 148A, and upon the issuance of CBDT Notifications dated 28.03.2022 and 29.03.2022, the authority to issue notice under section 148 vested exclusively in the Faceless Assessing Officer through automated allocation, and not in the Jurisdictional Assessing Officer. It was submitted that the issuance

Rajwant Kaur, Pehowa, Kurukshetra vs. ITO, Ward 3, Kurukshetra

In the result, the delay is condoned and the appeal is treated as allowed for statistical purposes

ITA 1023/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh09 Dec 2025AY 2012-13

Bench: The Tribunal With A Delay Of 408 Days. Along With The Appeal, The Assessee Has Filed An Application Seeking Condonation Of Delay. In The Condonation Petition, The Assessee Has Explained That She Is A Farmer By Occupation, Residing In A Rural Area & Has Very Limited Knowledge Of Income Tax Laws As Well As Online Procedures. It Has Been Stated That She Was Not Aware Of The Requirement To Check Or Respond Through The Income-Tax E-Filing Portal & Came To Know About The Demand Only Upon Receipt Of A Physical Notice From The Department. Thereafter, She Immediately Sought Professional Assistance. The Delay, According To The Assessee, Is Wholly Unintentional & Caused Due To Circumstances Beyond Her Control.

For Appellant: Shri Rajeev Sachdeva, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 148

hearing the Ld. Counsel for the assessee has raised several grounds challenging the validity of reassessment on account of non- service of notice under section 148, alleged non-speaking order on objections, incorrect appreciation of facts relating to transfer of ancestral agricultural land without consideration, and denial of opportunity

Parvatbhai Baria, Gujarat vs. ITO, Ward 1, Godhra, Gujarat

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

ITA 1583/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 1583/Ahd/2025 िनधा"रण वष"/Asstt. Year: 2018-2019 Parvatbhai Baria, The Income Tax Officer, बनामVs. 818, Vavdi Gam, Ward-1, Dahod Highway, Godhra. Vavdi Buzurg, Panchmahal-389001. Gujarat.

For Appellant: Shri Abbas Gulamhusianwala, ARFor Respondent: Shri Saresh Kartik Laxmanbhai, Sr. DR

Section 139(1)Section 142(1)Section 147Section 148Section 153CSection 250(6)Section 270ASection 45

income under section 139(1) of the Act. Based on the information available, the case of the assessee was reopened by issuing a notice under section 148 of the Act dated 29.03.2022. In response, the assessee filed a return of income on 02.03.2024 declaring total income