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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

ACIT, New Delhi vs. Vrinda Farms Private Limited, Delhi

In the result, appeal of the revenue is dismissed and the CO of the assessee is dismissed as infructuous

ITA 4694/DEL/2024[2012-13]Status: DisposedITAT Delhi28 Nov 2025AY 2012-13

Bench: Shri M. Balaganesh & Ms Madhumita Royacit, Vs. Vrinda Farms Pvt. Ltd, Central Circle-4 43, Community Centre, New Delhi Sakir Nagar So, New Friends Colony So, South East Delhi (Appellant) (Respondent) Pan: Aaacv0355L Co-10/Del/2025 (In Ita No. 4694/Del/2024) (Assessment Year: 2012-13) Vrinda Farms Pvt. Ltd, Vs. Acit, 43, Community Centre, Central Circle-4 Sakir Nagar So, New New Delhi Friends Colony So, South East Delhi (Appellant) (Respondent) Pan: Aaacv0355L

For Appellant: Shri Biren Shah, CA (though VC)For Respondent: Shri Dayainder Singh Sindhu, CIT DR
Section 132Section 143(3)Section 147Section 148Section 149Section 149(1)Section 153ASection 153CSection 153C(1)

Section 149 for the following reasons. It must at the outset be noted that Section 149 regulates the time within which a notice under Section 148 may be issued. It thus neither ventures nor attempts to regulate the search assessment powers that are available to be invoked in terms

Kusum Mittal, Sangrur vs. Income Tax Officer, Ward - Sangrur, Sangrur

In the result, the appeal of the assessee is allowed

ITA 941/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh27 Nov 2025AY 2015-16

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

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 147Section 148Section 151Section 69

dated 30.07.2022 by the Jurisdictional Assessing Officer is illegal in view of the notifications dated 28.03.2022 and 29.03.2022 which states that the notice under section 148 of the Act shall be issued through automated allocation only and the Ld. Jurisdictional Assessing Officer is not at legally competent to issue notice ... record. In the present case, the assessee originally filed return declaring total income of Rs.10,45,260/-. The Assessing Officer issued a notice under section 148 on 30.07.2022 on the basis of information flagged as High Risk CRIU/VRU relating to investment of Rs.94,71,000/- in purchase of commercial land

Income-Tax Officer, Ward-4(1)(1), Ahmedabad vs. Shree Vishvamurte Trad Invest Private Limited, Ahmedabad

In the result, the appeal filed by the assessee in ITA No

ITA 432/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115BSection 143(1)Section 147Section 148Section 68Section 69C

that each matter has to be considered separately on the basis of the facts of case considering the date of issuance of notices under section 148 under TOLA by the Revenue and thereafter date of supplying information to the assessee and date of passing of order under section 148A ... date of issuance of notice under section 148 of the Act so as to consider whether issuance notice under section 148 of the Act is within 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra) or not. 66. So far as Assessment

Cosmos Engitech Private Limited, Vadodara, Gujarat vs. Asst. Commissioner of Income Tax, Circle 1(1)(1), Vadodara

In the result, the appeal of the assessee is dismissed

ITA 1466/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Tr Senthil Kumarcosmos Engitech Private Ltd., The Assistant Vs. Plot No.85/2, Cosmos House, Commissioner Padra Road, Atladara, Of Income Tax, Vadodara-380015. Circle-1(1)(1), Vadodara. [Pan :Aaacc7647 J] (Appellant) .. (Respondent) Appellant By : Shri Tej Shah, Ar Respondent By: Shri Rameshwar P Meena, Sr. Dr Date Of Hearing 11.11.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri Tej Shah, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 35Section 35(1)(ii)

detailed assessment u/s 143(3). The appellant prays that the action taken by the A.O. under Section 147 and the issuance of notice under Section 148 are inappropriate, as it does not fulfil the legal requirements for reopening the assessment. Further, CIT (Appeals) has also erred in dismissing the appeal ... effect from 01.04.2011 vide Notification No. 3/2019 dated 25.01.2019, circulated on 28.02.2019. Consequently, the deduction claimed by the assessee was not allowable. Accordingly, notice under section 148 was issued on 12.07.2019 after recording reasons and obtaining due approval. In response, the assessee filed its return on 16.07.2019 declaring the same

Shree Vishvamurte Tradinvest Private Limited, Ahmedabad vs. ITO Ward 4 (1) (1), Ahmedabad

In the result, the appeal filed by the assessee in ITA No

ITA 103/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115BSection 143(1)Section 147Section 148Section 68Section 69C

that each matter has to be considered separately on the basis of the facts of case considering the date of issuance of notices under section 148 under TOLA by the Revenue and thereafter date of supplying information to the assessee and date of passing of order under section 148A ... date of issuance of notice under section 148 of the Act so as to consider whether issuance notice under section 148 of the Act is within 'surviving time' as per the direction of Hon'ble Apex Court in case of Rajeev Bansal (supra) or not. 66. So far as Assessment

Mr Ramsoch Dashrath Yadav, Pune vs. ITO, Ward-8(3), Pune

In the result, appeal of the assessee is partly allowed

ITA 2034/PUN/2025[2018-19]Status: DisposedITAT Pune27 Nov 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2034/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Mr.Ramsoch Dashrath Yadav, V 1.The Income Tax Officer, Tayappa Chawl, Near Urdu S Ward-8(2), Pune. School, Kharalwadi, Pimpri, Pune – 411018. 2.Assistant/Dy.Commission Er Of Income Tax/Income Tax Officer, National Faceless Assessment Centre, Delhi. Pan: Acypy0615P Appellant/ Assessee Respondent / Revenue Assessee By Dr.Prashant Munot Revenue By Shri Ambarnath Khule-Jcit(Through Virtual Hearing) Date Of Hearing 26/11/2025 Date Of Pronouncement 27/11/2025 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 30.06.2025 Emanating From The Assessment Order Passed Under

Section 131(1)Section 147Section 148Section 148ASection 250

Order passed under section 148A(d) of the Act, approval/sanction granted by the competent authority; invocation of jurisdiction under section 147; issue of Notice under section 148 of the Act; and the reopening of the assessment by the learned Assessing Officer as confirmed by the learned Commissioner of Income ... against the Returned Business Income of Rs.297,195/-in the Return of Income filed in response to Notice under section 148 of the of Act. ITA No.2034/PUN/2025 [A] 6. In any view of the matter and in any case, the invocation of jurisdiction under section

Dhanalakshmi, Chennai vs. ITO, Ncw-8(1), Chennai

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

ITA 2473/CHNY/2025[2015-16]Status: DisposedITAT Chennai27 Nov 2025AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.2473/Chny/2025 िनधा9रण वष9 /Assessment Year: 2015-16

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. M. Subashri, Addl. CIT (virtual)
Section 147Section 148Section 69A

assessee had made huge cash deposits in her bank accounts, but has not filled return of income, reopened the assessment by issuing notice under section 148 of the Act on 04.04.2022. Subsequently , Faceless Assessing Officer (hereinafter referred as “FAO”) has passed assessment order u/s. 147 r.w.s

Lalit Kumar Mohanlal Jain, Mumbai vs. ITO Ward 20(2)(1), Mumbai

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

ITA 6129/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Ms. Ridhisha Jain (virtually appeared)For Respondent: Shri Surendra Mohan (SR DR)
Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 250Section 272A(1)(d)

submitted that the assessee had filed the original return of income under section 139(1) of the Act. Subsequently, a notice under section 148 was issued for reopening of the assessment. During the reassessment proceedings, the Ld. AO observed that the assessee had claimed exemption under section

Lalita Bharatkumar Jain, Mumbai vs. DCIT Circle 20(1), Mumbai

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

ITA 6078/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Ms. Ridhisha Jain (virtually appeared)For Respondent: Shri Surendra Mohan (SR DR)
Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 250Section 272A(1)(d)

submitted that the assessee had filed the original return of income under section 139(1) of the Act. Subsequently, a notice under section 148 was issued for reopening of the assessment. During the reassessment proceedings, the Ld. AO observed that the assessee had claimed exemption under section

Lalita Bharatkumar Jain, Mumbai vs. DCIT Circle 20(1), Mumbai

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

ITA 6077/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Ms. Ridhisha Jain (virtually appeared)For Respondent: Shri Surendra Mohan (SR DR)
Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 250Section 272A(1)(d)

submitted that the assessee had filed the original return of income under section 139(1) of the Act. Subsequently, a notice under section 148 was issued for reopening of the assessment. During the reassessment proceedings, the Ld. AO observed that the assessee had claimed exemption under section

Ravindra Kumar Vishwanath Yadav, Mumbai vs. ITO Ward 28(2)(1), Mumbai

In the result, the assessee’s appeal is allowed

ITA 4960/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Nov 2025AY 2015-16

Bench: Shri Narender Kumar Choudhryassessment Year: 2015-16 Mr. Ravindrakumar Vishwanath The Ito, Ward 28 (2)(1), Yadav, Tower 6, Vashi Railway Room No.1118, Samta Nagar Vs. Station Commercial Sector 1A, Airoli, Navi, Complex, Vashi, Mumbai – 400708 Navi Mumbai – 400703. Pan – Acbpy0748G. (Appellant) (Respondent) Present For: Assessee By : Shri Dharan Gandhi. Revenue By : Shri Sunil Mathews, Ld. Sr. D.R. Date Of Hearing : 13.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.03.2024, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2015-16. 2. In This Case, The Assessing Officer (A.O.) Vide Assessment Order 11.03.2024 U/S. 147 R.W.S. 144 R.W.S. 144 B Of The Act, Has Made The Addition Of Rs. 14,75,000/- Being Variation In Respect Of Unexplained Investment U/S. 69 Of The Act.

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sunil Mathews, Ld. Sr. D.R
Section 147Section 148Section 149Section 149(1)(b)Section 250Section 3Section 69

counsel for the parties. It is not in dispute that the present petition relates to A.Y.2015-16. Further, it is also undisputed that the notice under Section 148 has been issued on 5th April 2022 which is at page 52 of the paper book. Once these are the facts, paragraphs ... that all the notices issued under Section 148 after 1st April 2021 for A.Y.2015-16 have to be dropped. In the present case, the Notice under Section 148 is dated 5 th April 2022 and therefore, has to be dropped. 8. The decision in Rajeev Bansal (supra) has been subsequently followed

Devender, Alwar vs. Income Tax Officer, Rewari

Appeal is allowed

ITA 4363/DEL/2025[2015-2016]Status: DisposedITAT Delhi27 Nov 2025AY 2015-2016

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Pradeep Dang, CAFor Respondent: Sh. Khitesh Gupta, Sr. DR
Section 131Section 132Section 132ASection 133ASection 147Section 148Section 148ASection 149(1)Section 153ASection 153C

under: “6. We heard the parties and perused the material on record. In order to examine the whether in assessee's case the notice under section 148 is time barred or not, we need to first look at the relevant provisions of the Act and the legal position ... judicial precedence. Section 149(1) of the Act contain the provisions with regard to the time limit for issue of notice under section 148 of the Act and the same reads as under – 149 - Time limit for notice. (1) No notice under section 148 shall be issued for the relevant

Dy. Commissioner of Income Tax, Noida vs. M/S Ace Mega Structure Private Limited, Noida

In the result, appeal of the assessee is allowed

ITA 4115/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

failure to comply with that requirement renders the assessment legally untenable. 28. In the present case, the AO did not issue a notice under section 148, nor did he follow the due process of law under the new reassessment framework, including recording of satisfaction and obtaining prior sanction from

Ace Mega Structures Private Limited, Uttar Pradesh vs. DCIT/ACIT Cen Cir, Noida

In the result, appeal of the assessee is allowed

ITA 4067/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

failure to comply with that requirement renders the assessment legally untenable. 28. In the present case, the AO did not issue a notice under section 148, nor did he follow the due process of law under the new reassessment framework, including recording of satisfaction and obtaining prior sanction from

Mohd. Alam Quershi, Moradabad vs. ITO Ward-1(1), Moradabad

In the result, the appeal of the assesse is allowed

ITA 3986/DEL/2025[2015-16]Status: DisposedITAT Delhi27 Nov 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Manish Agarwalmohd. Alam Quershi, Income Tax Officer, 0, Gol Kothi, Depduty Ganj, Ward-1(1), Moradabad-244001, Vs. Moradabad. Uttar Pradesh. Pan-Aadpq4002B (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Ca & Shri P.K. Mishra, Ca Department By Shri Manish Gupta, Sr. Dr 19.11.2025 Date Of Hearing Date Of Pronouncement 19.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A) In Short], Dated 17.02.2025 In Appeal No. Nfac/2014-15/10282979 Arising Out Of The Assessment Order Passed U/S 147 R.W.S. 144 Dated 19.05.2023 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That Case Of The Assessee Was Reopened On The Basis Of Information Received That There Were Larger Credits In The Bank Account Of The Assessee & There Is Mismatch In The Income Declared By The Assessee & Credits In The Bank Account & Accordingly, Notice U/S 148 Was Issued On 06.04.2021. Mohd. Alam Qureshi Vs. Ito Thereafter, In Terms Of The Order Of Hon’Ble Supreme Court In The Case Of Union Of India Vs. Ashish Agarwal & Ors. In Civil Appeal No. 3005/2002, The Said Notice Was Treated As Notice U/S 148A(2) Of The Act. After Passing The Order U/S 148A(D) Of The Act, A Fresh Notice U/S 148 Was Issued On 29.07.2022. In Response, The Assessee Filed The Return On 28.08.2022 Declaring Total Income Of Rs. 3,90,230/-. The Assessment Was Completed U/S 147 R.W.S. 144B At An Income Of Rs. 58,64,382/- By Making Addition Of Rs. 54,74,132/-.

Section 147Section 148Section 148ASection 148A(2)

TOLA apply "notwithstanding anything contained in the specified Act." Section 3(1), therefore, overrides the time limits for issuing a notice under Section 148 read with Section 149 of the Income Tax Act; d. TOLA does not extend the life of the old regime. It merely provides a relaxation ... Revenue between 1 April 2021 and 30 June 2021 as show-cause notices in terms of Section 148A(b). Thereafter, the Revenue issued notices under Section 148 of the new regime between July and August 2022. Invalidation of the Section 148 notices issued under the new regime on the ground

Assisstant Commissioner of Income Tax, Ghaziabad vs. Arun Kumar, Ghaziabad

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

ITA 1035/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Nov 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwal & C.O 118/Del/2025 Assessment Year: 2014-15 Assistant Commissioner Of Vs. Arun Kumar Income Tax 201-202, 2Nd Ii-F-3 Nehru Nagar Ghaziabad Floor Cgo Complex 201001 Uttar Pradesh Hapur Chungi Ghaziabad -201002 Pan No. Aeapk1314B (Appellant) (Respondent) Appellant By Ms. Ankush Kalra, Sr.Dr Respondent By Dr. Rakesh Gupta, Adv Shri Somil Agarwal Adv

Section 10(38)Section 143(3)Section 147Section 148Section 151(2)Section 67Section 68

Deputy Commissioner of income tax [2008] 296ITR 90 Bombay held that if the Assessing Officer does not accept the objection filed to notice under section 148, he shall not proceed further in the matter for a period of four weeks from the date of receipt of service of the said

Deepak Kumar Agrawal S/O Shri Late Ratan Lal Agrawal, Tikamgarh vs. ITO, Tikamgarh

In the result, the appeal of the Assessee is partly allowed

ITA 445/AGR/2025[2012-13]Status: DisposedITAT Agra26 Nov 2025AY 2012-13

Bench: Shri M. Balaganesh(Through Virtual Hearing) Deepak Kumar Agrawal, Vs. Ito, Ward No. 12, Purani Tikamgarh Tehsil, New Housing Board, Mp (Appellant) (Respondent) Pan: Axapa3069L Assessee By : None Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 18/11/2025 Date Of Pronouncement 26/11/2025

For Appellant: NoneFor Respondent: Shri Anil Kumar, Sr. DR
Section 142(1)Section 143(3)Section 144Section 148

formed a belief that the income of the Assessee had escaped assessment to the extent of cash deposits and proceeded to issue notice under Section 148 of the Act on 21-03-2018 after recording reasons thereon. The reasons recorded by the learned AO for reopening the assessment are reproduced ... page 2 of the re-assessment order. In response to the said notice under Section 148 of the Act, no return was filed Deepak Kumar Agrawal by the Assessee. Further, a notice under Section 142(1) of the Act was issued on 9-08-2018 in Hindi

Shobha Devi, Jhansi vs. Income Tax Officer, Jhansi, Up

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

ITA 429/AGR/2025[2018-19]Status: DisposedITAT Agra26 Nov 2025AY 2018-19

Bench: Shri M. Balaganesh(Through Virtual Hearing) Shobha Devi, Vs. Income Tax Officer, 285, Suri Wali Gali, Ward-2(3)(1), Near Masjid Pratap Jhansi Pura Nagar, Sipri Bzaaar, Jhansi, Up (Appellant) (Respondent) Pan: Ainpd4091R Assessee By : None Revenue By: Shri Anil Kumar, Sr Dr Date Of Hearing 17/11/2025 Date Of Pronouncement 26/11/2025

For Appellant: NoneFor Respondent: Shri Anil Kumar, Sr DR
Section 144BSection 147Section 148Section 69

source of investment was also not explained by the Assessee, the proceedings under section 147 stood initiated on the Assessee vide issuance of notice under section 148 of the Act on 31-03-2022. The re-assessment was ultimately completed under Section 147 r.w. Section144B

Pawan Agrawal, Mathura vs. Income Tax Officer 1(3)(1), Mathura

ITA 386/AGR/2025[2020-21]Status: DisposedITAT Agra26 Nov 2025AY 2020-21

Bench: Shri M. Balaganesh(Through Virtual Hearing)

For Appellant: Shri M. M. Agarwal, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 132Section 147Section 148Section 151

Vrindavan during the year under consideration. For this purpose, the case of the Assessee was sought to be reopened after vide issuance of notice under section 148 of the Act on 29-3-2024 after obtaining the prior approval of the Learned PCIT-1, Agra in terms of section ... response to the notice under Section 148 of the Act dated 29-3-2024, the Assessee filed his return of income on 3-7-2024 declaring taxable income of Rs. 3,02,110/-. The reassessment was later completed under Section 147 of the Act on 1-3-2025 determining total

Pankaj Sujoria, Mansarovar Colony vs. ITO 1(1), Gwl, Gwalior

In the result, the appeal of the Assessee is allowed

ITA 323/AGR/2025[2011-12]Status: DisposedITAT Agra26 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Pankaj Sujoria, Vs. Ito, A-481, Mansarovar Ward-1(1), Colony, Shahpura, Gwalior Bhopal, Mp (Appellant) (Respondent) Pan: Arzps0280L Assessee By : None Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/11/2025 Date Of Pronouncement 26/11/2025

For Appellant: NoneFor Respondent: Shri Anil Kumar, Sr. DR
Section 139Section 144Section 147Section 148

year under consideration, the case of the Assessee was sought to be reopened under section 147 of the Act vide issuance of notice under section 148 of the Act on 28-03-2018 which was duly served on the Assessee on 31-03-2018. No return has been filed