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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

Go Iron Marketing, Visakhapatnam vs. Income Tax Officer, Ward 3(3), Vishakapatnam

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

ITA 483/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.483/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Go Iron Marketing, Vs. Income Tax Officer, Visakhapatnam. Ward-3(3), Pan: Aanfg6474D Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca (Hybrid Hearing) राज" व "ारा/Revenue By: Shri Badicala Yadagiri, Cit-Dr सुनवाई की तारीख/Date Of 03/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 26/07/2025 Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 01/02/2024 For The Assessment Year 2018-19. The 2 Go Iron Marketing Vs. Ito

For Appellant: Mrs. K. Hemalatha, CAFor Respondent: Shri Badicala Yadagiri, CIT-DR
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 151ASection 250

threshold of hearing of the appeal, submitted that both the impugned order passed under Section 148A(d) of the Act, dated 31/03/2022 and Notice under Section 148 of the Act, dated 01/04/2022 issued by the Jurisdictional Assessing Officer (JAO), i.e., outside the faceless mechanism as provided under the provisions ... Authorities Scheme, 2022" and the "e-Assessment of Income Escaping Assessment Scheme, 2022", only the “Faceless Assessing Officer” (FAO) can issue the notice under Section 148 of the Act and not the “Jurisdictional Assessing Officer” (JAO), but the same was rejected by the CIT(A). Elaborating further on her contention

Assistant Commissioner of Income Tax, Guntur vs. Donkala Chenchu Narasimha Rao, Nellore

In the result, appeal of the revenue is dismissed

ITA 460/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2019-20

Bench: Shri Ravish Sood, Hon’Ble

Section 133ASection 147Section 148Section 69

contained in Impounded Material, it was noticed that the assessee has paid certain amount of cash on 22.01.2015 for purchasing immovable property. Thereafter, notice under section 148 of the Act was issued on 30.03.2021 and in response assessee filed return of income on 20.04.2021 admitting the income declared

No 368 Kolakaluru Primary Agricultural Co Operative Credit Society Limited, Guntur vs. Income Tax Officer, Ward-1, Tenali

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

ITA 456/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.456/Viz/2025 (िनधा"रण वष"/Assessment Year:2019-20) No.368 Kolakaluru Primary Vs. Income Tax Officer, Agricultural Cooperative Ward-1, Credit Society Limited, Tenali. Tenali. Pan: Aaban6994Q (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 04/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Society Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W Section 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144Section 144BSection 147Section 148Section 148ASection 151Section 151ASection 80PSection 80P(2)(a)Section 80P(2)(d)

District Co-operative Central Bank Limited, but had not filed its return of income, initiated proceedings under section 147 of the Act. Accordingly, notice under section 148 of the Act, dated 30/03/2023, was issued to the assessee society. 3 No.368 Kolakaluru Primary Agricultural Cooperative Credit Society Limited ... 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

Donkala Chenchu Narasimha Rao, Nellore vs. The Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeal of the revenue is dismissed

ITA 408/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble

Section 133ASection 147Section 148Section 69

contained in Impounded Material, it was noticed that the assessee has paid certain amount of cash on 22.01.2015 for purchasing immovable property. Thereafter, notice under section 148 of the Act was issued on 30.03.2021 and in response assessee filed return of income on 20.04.2021 admitting the income declared

Shakir Mohmmad, Visakhapatnam vs. The Income Tax Officer, Ward-2(5), Visakhapatnam

ITA 280/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.280/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Shakir Mohmmad, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Cffpm2965E Visakhapatnam. (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 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

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

dated 31/03/2022 was passed by the Income Tax Officer, Ward-3(1), Visakhapatnam, i.e., the Jurisdictional Assessing Officer (JAO). Thereafter, the JAO issued notice under section 148 of the Act, dated 31/03/2022. 5. Thereafter, the AO vide his order passed under section 147 r.w.s 144 of the Act, dated 25/03/2023 ... submitted that the assessee in the course of hearing of the appeal had vide his written submissions specifically challenged the validity of the notice under section 148 of the Act, dated 31/03/2022 that was issued by the ITO, Ward-3(1), Visakhapatnam, i.e., the JAO, inter alia, on the ground

A & B Associates, Thiruvananthapuram vs. The Income Tax Officer, Thiruvananthapuram

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

ITA 643/COCH/2025[2018-19]Status: DisposedITAT Cochin05 Dec 2025AY 2018-19

Bench: the Ld. CIT(A). The Ld.CIT(A) partly allowed the appeal filed by the assessee by directing the AO to -

For Appellant: Shri Lokanathan, C.AFor Respondent: Shri Sanjit Kumar Das, Sr. D/R
Section 115BSection 142(1)Section 144Section 147Section 148Section 148ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH,COCHIN BEFORESHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL

Bhavna Shetalkumar Patel, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 1103/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad05 Dec 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Parin S Shah, ARFor Respondent: Shri Santosh Kumar, Sr. DR
Section 10(38)Section 142(1)Section 143(1)Section 144Section 144BSection 147Section 148Section 68

penny stock scrips, including Jackson Investments Ltd., the Assessing Officer formed a belief that income chargeable to tax had escaped assessment and issued notice under section 148 on 31.03.2021. The Assessing Officer proceeded on the assumption that the assessee had not disclosed the impugned transaction. 6. In response, the assessee ... during assessment proceedings, has not been shown to be incorrect. It is also relevant to note that the return in response to the notice under section 148 was filed almost after one year from the issuance of the notice, and the assessee's first effective reply to the statutory notices

Dy Commissioner of Income Tax Circle 5 Pune, Pune vs. Dipti Narendra Lulla, Pune

ITA 1065/PUN/2025[2018-19]Status: DisposedITAT Pune05 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

Section 143(2)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

Gavini Giridhara Murari, Tirupati vs. ITO., Ward-1(1), Tirupati

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

ITA 709/HYD/2025[2016-17]Status: DisposedITAT Hyderabad05 Dec 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: N ON E
Section 147Section 148Section 69A

assessee was reopened for the assessment year 2016-17 under section 147 of the Income Tax Act, 1961 (“the Act”) and accordingly notice under section 148 of the Act was issued on 20.03.2023 by the Learned Assessing Officer (“Ld. AO”). However, in response to the said notice, the assessee

Venkata Ramanamma Sakamuri, Marripadu, Nellore vs. ITO., Ward-1, Nellore

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

ITA 299/HYD/2025[2019-20]Status: DisposedITAT Hyderabad05 Dec 2025AY 2019-20

Bench: Us:

Section 144Section 148Section 148A

that the assessee, despite having carried out the aforesaid substantial financial transactions, had not filed his return of income for the subject year. Notice under section 148 of the Act, dated 31/03/2023, was issued to the assessee. 3. As the assessee neither filed his return of income in compliance ... without success. 6. On a perusal of the CIT(A) order, we find that though the assessee has assailed the validity of the notice under section 148 of the Act by the “Jurisdictional Assessing Officer” (JAO), but, the appellate authority had, after drawing support from the judgment

Sanghi Textiles Private Limited, Hyderabad vs. Income Tax Officer, Ward-3(1), Hyderabad

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

ITA 758/HYD/2024[2013-14]Status: DisposedITAT Hyderabad05 Dec 2025AY 2013-14

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.758/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2013-14) M/S Sanghi Textiles Vs. Income Tax Officer Private Limited Ward 3(1) Hyderabad Hyderabad Pan:Aadcs0837P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 25/11/2025 घोषणा की तारीख/Pronouncement: 05/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Dr. Sachin Kumar, Sr. DR
Section 147Section 148Section 271BSection 274Section 44A

delayed. Additionally Tribunal held that appellant did not file the income tax return voluntarily but it was in response to a notice under section 148 of the Act. 9. In view of above, Tribunal confirmed the levy of penalty. 10. We do not find any error or infirmity

Shankeshwar Exim LLP, Mumbai vs. ITO - 19(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5117/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 148Section 250Section 69C

raised on merits would become academic. 4. We heard the parties and perused the material on record. The ld. AR submitted that the notice under section 148 dated 26.04.2022 is beyond the period of 3 years and therefore as per the provisions of Section ... further submitted that in the present case the AO has obtained approval from Principle Commissioner of Income Tax (PCIT) while issuing notice under section 148 and therefore the notice is invalid. In this regard, we notice that the Hon'ble Bombay High Court in the case of M/s. Vodafone Idea

Diamond Realcon Private Limited, Delhi vs. ACIT, Central Circle-2, Faridabad

In the result, Appeal in ITA

ITA 1260/DEL/2025[2012-13]Status: DisposedITAT Delhi05 Dec 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

declaring loss of Rs. 72,839/- for the year under consideration. The case of the Assessee was selected for re-assessment by issuing notice under Section 148 of the Act. The A.O. completed the assessment proceedings u/s 147 r.w. Section 144 of the Act vide order dated 28/12/2018 by making

Diamond Realcon Private Limited, New Delhi vs. ACIT, Central Circle-2, Faridabad

In the result, Appeal in ITA

ITA 1259/DEL/2025[2011-12]Status: DisposedITAT Delhi05 Dec 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Ita No. 1260/Del/2025 (A.Y. 2012-13) M/S Diamond Realcon Private Vs Assistant Commissioner Of Limited, Income Tax, Central Circle-Ii, Shop No. 68, Building No. 38, Faridabad, Surya House, Near Pnb, Devli, Haryana-121001 Khanpur, New Delhi-110062 Pan: Aadcd6696H Appellant Respondent Assessee By Sh. S. S. Nagar, Ca Revenue By Ms.Suman Malik, Cit Dr Date Of Hearing 08/09/2025 Date Of Pronouncement 05/12/2025

Section 143(2)Section 147Section 148Section 151Section 153CSection 68

declaring loss of Rs. 72,839/- for the year under consideration. The case of the Assessee was selected for re-assessment by issuing notice under Section 148 of the Act. The A.O. completed the assessment proceedings u/s 147 r.w. Section 144 of the Act vide order dated 28/12/2018 by making

Income Tax Officer, Delhi vs. Pankaj Enterprises Pvt. Ltd., New Delhi

The appeal of the revenue stands dismissed

ITA 4188/DEL/2024[2015-16]Status: DisposedITAT Delhi05 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwalincome Tax Officer Vs. Pankaj Enterprises Pvt. Room No.217, Cr Ltd., 130, First Floor, Building, D-Mall, Netaji Subhash New Delhi – 110002 Place, Pitampura, Saraswati Vihar, North West Delhi, Delhi - 110034 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcp9429N Appellant .. Respondent C.O. No.83/Del/2025 (Assessment Year:2015-16) Pankaj Enterprises Pvt. Vs. Ito, Ward 19(3) Ltd., 130, First Floor, Room No.217, Cr D-Mall, Netaji Subhash Building, Place, Pitampura, New Delhi – 110002 Saraswati Vihar, North West Delhi, Delhi - 110034 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcp9429N Appellant .. Respondent

For Appellant: Ms. Shilpi Jain, CAFor Respondent: Sh. Krishna Kumar Ramawat, Sr
Section 13Section 147Section 148Section 282Section 282(1)

find that assessee has raised a legal ground No. 1 that the assessment order passed by the AO is invalid as a notice under Section 148 of the Act dated 31.03.2021 is time barred. 3. Although ld. DR has defended the ground however what is material is that the evidence ... email received by the assessee P a g e | 3 ITA No. 4188/Del/2024 CO 83/Del/2025 Pankaj Enterprises Pvt. Ld. (AY: 2015-16) serving notice under Section 148 of the Act on the assessee available at page 19.1 of the paper book goes to show that

Deputy Commissioner of Income Tax, Ghaziabad vs. Mahalakshmi Light House, Hapur

In the result, Cross Objection filed by the Assessee is allowed

ITA 3513/DEL/2024[2015-16]Status: DisposedITAT Delhi05 Dec 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Deputy Commissioner Of Vs. Mahalakshmi Light House, Income Tax 285, Avas Vikas Vihar, Room No. 201, First Floor, Hapur, Uttar Pradesh Cgo Complex, Hapur Chungi, Pan: Aatfm3627N Ghaziabad, Uttar Pradesh Appellant Respondent

Section 147Section 69C

which the assessee informed the Assessing Officer that the return originally filed should be treated as the return filed pursuant to the notice under section 148 of the Act. 13. In DIT v. Society for Worldwide Interbank Financial Telecommunications [2010] 323 ITR 249 (Delhi), this court invalidated a reassessment proceeding ... /Del/2024 DCIT Vs. Mahalaxmi Light House claim. In view of the above, after receipt of return in response to notice under section 148, it shall be mandatory for the Assessing Officer to serve a notice under sub-section (2) of Section 143 assigning reason therein . . . in absence of any notice

Vimalarjun Trust, Lucknow vs. ACIT, Central Circle-2, Delhi

In the result, the appeal of assessee is allowed

ITA 2094/DEL/2024[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2017-18 Vimalarjun Trust, Vs. Acit, 2/652, Vikram Khand, Gomti Circle-2, Nagar, Lucknow Delhi Uttar Pradesh Pin: 226010 Pan No. Aabtv7815R (Appellant) (Respondent)

For Appellant: Shri Ved Jain, Advs. & Shri PawanFor Respondent: Shri Sanjay Kaushal, CIT DR
Section 133ASection 139Section 142(1)Section 143(1)Section 143(2)Section 153Section 153CSection 250

Officer's jurisdiction to undertake proceedings has to be tested/examined only on the basis of reasons recorded at the time of issuing a notice under section 148 of the Act seeking to reopen an assessment. These reasons cannot be improved upon and/or supplemented.” 5.9 On plain reading of satisfaction note

Income Tax Officer, Ashoknagar vs. Ajit Singh, Shivpuri

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

ITA 89/AGR/2025[2013]Status: DisposedITAT Agra04 Dec 2025

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Income Tax Officer, Vs. Ajit Singh, Ashoknagar, Village-Haatodh, Madhya Pradesh Post-Kota, Shivpuri (Appellant) (Respondent) Pan: Ccnps7470K Assessee By : Shri Vipin Upadhyay, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 17/11/2025 Date Of Pronouncement 04/11/2025

For Appellant: Shri Vipin Upadhyay, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT(DR)
Section 133(6)Section 139Section 142(1)Section 143(2)Section 143(3)Section 144Section 144BSection 147Section 148Section 148(1)

Learned AO proceeded to reopen the assessment under section 147 of the Act after obtaining necessary approval of the competent authority. Accordingly, notice under section 148 of the Act stood issued to the Assessee on 30-3-2021, which was duly served on the Assessee ... This assessment was framed by the Learned JAO, Income Tax Officer, Ajit Singh Ashok Nagar. It is pertinent to note that both the notice under section 148 of the Act was issued by the Learned JAO and reassessment was framed by the Learned JAO. 6. The Assessee filed detailed submissions

Anju Agarwal, Agra vs. Income Tax Officer, Ward 2(1)(1), Agra

In the result, the appeal of the Assessee is allowed

ITA 320/AGR/2025[2019-20]Status: DisposedITAT Agra04 Dec 2025AY 2019-20

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Anju Agarwal, Vs. Income Tax Officer, D-26, Kamla Nagar, Ward-2(1)(1), Agra Agra (Appellant) (Respondent) Pan: Awtpa4297L Assessee By : Shri K. K. Jain, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: Shri K. K. Jain, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133ASection 147Section 148Section 148ASection 151Section 68

reply to be unacceptable and proceeded to pass an order under Section 148A(d) of the Act dated 27-3-2023. Accordingly, notice under Section 148 of the Act stood issued to the Assessee on 27-3-2023 after taking prior approval under Section 151 of the Act from

Neeta Agarwal, Agra vs. Income Tax Officer, 2(1)(2), Agra

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

ITA 213/AGR/2025[2016-17]Status: DisposedITAT Agra04 Dec 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Neeta Agarwal, Vs. Income Tax Officer, E-23, New Agra, Agra Ward-2(1)(2), Agra (Appellant) (Respondent) Pan: Aaxpa0936E Assessee By : Shri Amit Goyal, Adv Shri Nitin Goyal, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 16/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: Shri Amit Goyal, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 10(38)Section 143(3)Section 148Section 151Section 234BSection 271(1)Section 68Section 69C

gains of Rs. 94,59,175/- thereon, proceeded to deny the exemption under Section 10(38) of the Act to the Assessee. Accordingly, notice under Section 148 of the Act dated 30-03-2021 was issued and served upon the Assessee. The Assessee filed her return of income ... exempt under Section 10(38) of the Act on account of long-term capital gain, in response to the notice under Section 148 of the Act dated 30-03-2021. The reassessment ultimately stood completed by treating M/s Capital Trade Link Ltd as a penny stock and the sale proceeds