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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

M/S Bajrang Lal Jindal, Kanpur vs. Astt. Commissioner of Income Tax-I, Kanpur

In the result, the appeal of the assessee is allowed

ITA 373/LKW/2017[2008-09]Status: DisposedITAT Lucknow20 Nov 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2008-09 M/S Bajrang Lal Jindal, 140, Vs. Asstt. Commissioner Of Income Anandpuri, Kanpur, U.P. Tax-I, Kanpur Pan: Aanpj5660J (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 27.08.2025 Date Of Pronouncement: 20.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A)- Kanpur, Confirming The Addition Of Rs. 1,46,11,400/- Made To The Returned Income Of The Assessee As Unexplained Cash Credits By The Assessing Officer In His Order Dated 31.03.2016 For The Assessment Year 2008-09. The Grounds Of Appeal Are As Under: - “1. That The Ld. Cit (A) I, Kanpur Has Erred In Confirming Addition Of Rs. 14611400.00 To The Returned Income Of The Assessee As Unexplained Cash Credits. 2. That The Reasons Recorded For Initiation Of Proceedings U/S 147 By Issue Of Notice U/S 148 Were Based On Improper Premise & Accordingly No Legal & Factual Lengs To Stand & Acordingly All Subsequent Proceedings Are Bad In Law. 3. That The Observation Of The Ld. Cit (A) I, Kanpur Confirming View Of Ld. A O That M/S. Maa Devasar Commodity Is Inexistant Is Factually Incorrect. 4. That Ld. Cit (A) I, Kanpur Has Erred In Not Appreciating The Fact That When The Beneficiary Of The Funds Are Not The Assessee, There Could Be No Addition In His Hands.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. Amit Kumar, DR
Section 147Section 148Section 68

accounts maintained at ICICI Bank, were nothing but the assessee’s own money which was being routed through these bank accounts. Accordingly, a notice under section 148 was issued on the basis of this information, that was received from the Investigation Wing. The assessee was required to explain the nature ... Investigation Wing and initiated proceedings under section 148 on the basis of this borrowed satisfaction which made the issue of the notice under section 148 itself invalid. For this proposition, the ld. AR relied upon the orders of the ITAT Delhi ‘F’ Bench in the case Udesh Sharma

Ronak Gupta, Hyderabad vs. ACIT., Central Circle -3(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 965/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.965/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Ronak Gupta Vs. Asstt. Cit Hyderabad Circle 3(1) Pan:Aiapg3319G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. Siddharth Toshnival राज" व "ारा/Revenue By:: Shri Ranjan Agarwala, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/11/2025 घोषणा की तारीख/Pronouncement: 21/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Ronak Gupta (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad (“Ld. Cit(A)”) Dated 30.03.2025 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Adv. Siddharth ToshnivalFor Respondent: : Shri Ranjan Agarwala, Sr. DR
Section 132Section 143(1)Section 143(3)Section 144Section 147Section 148Section 148ASection 153A

153A of the Act determining total income of the assessee at Rs.39,89,130/-. Later, the case of the assessee was reopened and notice under section 148 of the Act (old regime) was issued to the assessee on 30.06.2021. In response to the said notice, the assessee did not file ... accordance with the judgment of the Hon’ble Supreme Court in the case of UOI vs. Ashish Agarwal (444 ITR 1). The earlier notice under section 148 of the Act dated 30.06.2021 was treated as a notice under section 148A(b) of the Act and a fresh reassessment order under

Tirupati Timbers & Packaging P. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1428/KOL/2025[2011-2012]Status: DisposedITAT Kolkata20 Nov 2025AY 2011-2012

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1428/Kol/2025 Assessment Year: 2011-2012 Tirupati Timbers & Packaging P. Limited,…Appellant Room No. 563, Marshall House, 33/1, N.S. Road, Dalhousie, G.P.O., Kolkata-700001, W.B. [Pan:Aabct2720Q] -Vs.- Income Tax Officer,……………………………..Respondent Ward-4(1), Kolkata, Aayakar Bhawan, 8Th Floor, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Girdhar Dhelia, Advocate, Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 02, 2025 Date Of Pronouncing The Order: November 20, 2025 O R D E R

Section 142(1)Section 143(2)Section 147Section 148Section 154Section 250

Kolkata, the assessment was reopened under section 147 of the Act after taking approval from the ld. PCIT-2, Kolkata on 30.03.2018 and notice under section 148 of the Act was issued to the assessee-company. The assessee-company filed its return of income in response to notice under section

Sowmya Kannan, Chennai vs. ITO, Ward-19(4), Chennai

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

ITA 2524/CHNY/2025[2015-16]Status: DisposedITAT Chennai20 Nov 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2524/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Ms. Sowmya Kannan, The Income Tax Officer, No.634-A, Ramasamy Salai, Vs. Non-Corporate Ward 19(4), K K Nagar, Chennai. Chennai – 600 078. Pan: Aaopk 5170F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Abhishek Murali, Ca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 20.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 20.11.2025

For Appellant: Shri Abhishek Murali, CAFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144BSection 147Section 148Section 148ASection 250

outset, we notice that the assessee has filed addition grounds of appeal challenging the validity of the assumption of jurisdiction for issuance of notice under section 148 of the Act. The Ld.AR vehemently argued that the notice under section 148 of the Act issued by the Income Tax Officer ... material on record. By way of Additional grounds of appeal, the assessee has raised legal issue of assumption of jurisdiction for issuance of notice under section 148 of the Act. Since the additional ground raised by the assessee relate to a pure legal issue, which does require examination

ITO(It)-3(2)(1), Mumbai vs. Shapoorji Pallonji Mistry, Mumbai

ITA 3674/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Nov 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

sanction u/s.151 of the case has been obtained as per the CBDT Instruction No.1/2022 dated 11.05.024 wherein it has been specified that fresh notice under section 148 is to be issued for AY 2016-17 with the approval of the specified authority under clause (i) of section ... issue of notice u/s.148 of the Act. Section 149 of the Act reads as under: Time limit for notice. 149. (1) No notice under section 148 shall be issued for the relevant assessment year,- (a) if three years have elapsed from the end of the relevant assessment year, unless

Income Tax Officer (It)-3(2)(1), Kautilya Bhawan vs. Shapoorji Pallonji Mistry, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 3523/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Nov 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. Advocate and Shri Divesh Chawla, AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

case has been obtained as per the CBDT Instruction No.1/2022 dated 11.05.024 wherein it has been specified that fresh notice under section 148 is to be issued for AY 2016-17 with the approval of the specified authority under clause (i) of section 151 of the Act, i.e., the Pr.CIT ... issue of notice u/s. 148 of the Act. Section 149 of the Act reads as under: Time limit for notice. 149. (1) No notice under section 148 shall be issued for the relevant assessment year,- (a) if three years have elapsed from the end of the relevant assessment year, unless

Income Tax Officer (International Taxation) 3(2)(1), Kautilya Bhawan Mumbai vs. Shapoorji Pallonji Mistry, Mumbai

ITA 3440/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Nov 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Satya Pal Kumar - CIT DR
Section 147Section 148Section 148ASection 149Section 151Section 3Section 3(1)

sanction u/s.151 of the case has been obtained as per the CBDT Instruction No.1/2022 dated 11.05.024 wherein it has been specified that fresh notice under section 148 is to be issued for AY 2016-17 with the approval of the specified authority under clause (i) of section ... issue of notice u/s.148 of the Act. Section 149 of the Act reads as under: Time limit for notice. 149. (1) No notice under section 148 shall be issued for the relevant assessment year,- (a) if three years have elapsed from the end of the relevant assessment year, unless

Magnolia Martinique Clothing Private Limited, Delhi vs. DCIT, Central Circle 17, New Delhi, Delhi

In the result, all the appeals filed by the assessee are partly allowed

ITA 4293/DEL/2025[2016-17]Status: DisposedITAT Delhi20 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

For Appellant: Shri Dushayant Chaudhary, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 142(1)Section 147Section 148

void ab initio. 2. The CIT(A) erred in not quashing the reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income

Magnolia Martinique Clothing Private Limited, Delhi vs. DCIT, Central Circle 17, New Delhi, Delhi

In the result, all the appeals filed by the assessee are partly allowed

ITA 4292/DEL/2025[2015-16]Status: DisposedITAT Delhi20 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

For Appellant: Shri Dushayant Chaudhary, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 142(1)Section 147Section 148

void ab initio. 2. The CIT(A) erred in not quashing the reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income

Magnolia Martinique Clothing Private Limited, Delhi vs. DCIT, Central Circle 17, New Delhi, Delhi

In the result, all the appeals filed by the assessee are partly allowed

ITA 4291/DEL/2025[2014-15]Status: DisposedITAT Delhi20 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

For Appellant: Shri Dushayant Chaudhary, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 142(1)Section 147Section 148

void ab initio. 2. The CIT(A) erred in not quashing the reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income

Magnolia Martinique Clothing Private Limited, Delhi vs. DCIT, Central Circle-17, New Delhi, Delhi

In the result, all the appeals filed by the assessee are partly allowed

ITA 4290/DEL/2025[2013-14]Status: DisposedITAT Delhi20 Nov 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S.Rifaur Rahman

For Appellant: Shri Dushayant Chaudhary, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 142(1)Section 147Section 148

void ab initio. 2. The CIT(A) erred in not quashing the reassessment proceeding, initiated under section 148A despite the fact that the notice under section 148 issued on 30.06.2021 was beyond the permissible limitation period as per amended section 149(1)(b), and no valid "asset” representing escaped income

Om Prakash, Hathras vs. Income Tax Officer, Ward 4(3)(4), Hathras

In the result, the appeal of the assessee is allowed

ITA 153/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Om Prakash, Vs. Income Tax Officer, Village Baramai, Ward-4(3)(4), Sadabad, Hathras Hathras (Appellant) (Respondent) Pan: Dkbpp7713K

For Appellant: Shri Rajesh Malhotra, CAFor Respondent: Shri Anil Kumar, Sr. DR
Section 144Section 147Section 148Section 151

income for the year under consideration. Accordingly, the Learned AO formed a belief that income of the assessee had escaped assessment and issued notice under Section 148 of the Act on 26-03-2018 after obtaining approval from the Ld PCIT, Aligarh. The reasons recorded for reopening the assessment

Anil Kumar Agarwal, Agra vs. DCIT 2(1)(1), Agra

In the result, the appeal of the assessee is allowed

ITA 101/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Anil Kumar Agarwal, Vs. Dy. Cit, 44, R. S. Residency, Circle-2(1)(1), Dayal Bagh, Agra, Up Agra (Appellant) (Respondent) Pan: Aampa3335J Assessee By : Shri Rajni Kant Verma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Rajni Kant Verma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 133(6)Section 143(3)Section 148Section 68

deposit made by the assessee to the extent of Rs. 13 lakhs in the bank account maintained with HDFC bank , Sanjay Place, Agra, notice under Section 148 of the Act stood issued to the assessee on 27-03-2018 on the ground, cash deposit represent income escaping assessment

Radhika Garg, Hathras vs. Income Tax Officer, Ward-2(1)(3), Agra

In the result, the appeal of the assessee is allowed

ITA 433/AGR/2024[2012-13]Status: DisposedITAT Agra19 Nov 2025AY 2012-13

Bench: Shri M. Balaganesh(Through Virtual Hearing) Radhika Garg, Vs. Income Tax Officer, 14/100, Kambhu Tola Ward-2(1)(3), Hospital Road, Hathras, Up Agra (Appellant) (Respondent) Pan:Afepg2999H Assessee By : Shri Anurag Sinha, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Anurag Sinha, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 142(1)Section 143(2)Section 144Section 147Section 148Section 292B

Savings Bank maintained with State Bank of India in Account Number 10114169760. Pursuant to this information, notice under section 148 of the Act stood issued to the assessee on 31-03-2019. In response to the said notice, the return of income was filed by the assessee ... reassessment proceedings, an addition on account of unexplained gift was sought to be examined and made. In the said reassessment proceedings, notice under section 148 of the Act was issued by the assessing officer on 26-12-2000. The assessee responded to the notice under section 148

Alok Kumar, Madhepura vs. ITO Ward 3(5), Saharsa

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

ITA 467/PAT/2024[2012-13]Status: DisposedITAT Patna19 Nov 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraalok Kumar, Ito Ward-3(5), S/O Sri Dasrath Mehata, Saharsha Village- Ganeshpur, M.S. Vs Yogiraj, Purani Madhepura, Dist- Madhepura – 852116 (Bihar) (Pan: Bpkpk1186D) (Appellant) (Respondent) Present For: Appellant By : K.P. Jalan, Ar Respondent By : Ashwani Kr. Singal, Jcit Date Of Hearing : 16.10.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per Rakesh Mishra: This Appeal Filed By The Assessee Is Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Ld. Cit(A) Dated 14.05.2024. 2 Alok Kumar, Ay: 2012-13 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: K.P. Jalan, ARFor Respondent: Ashwani Kr. Singal, JCIT
Section 147Section 148Section 2Section 292BSection 54F

sale of land worth ₹1,66,07,000/- as the assessee was found to have sold 2 pieces of land and a notice under section 148 of the Act was issued. In pursuance to the notice u/s 148 dt. 25.03.2019, the assessee had filed ITR-2 on 25.05.2019, however

Gmedapadu Pacs, East Godavari vs. ITO, Ward-1, Kakinada

ITA 573/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.573/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Gmedapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Kss Sarma, Ca रधजस् व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 16/10/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: 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 18/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 10/02/2021 For Ay 2018-19. The Assessee Society Has Assailed The Impugned Order Passed By The Ao On The Following Grounds Of Appeal:

For Appellant: Sri KSS Sarma, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 80P

ruling in GKN Driveshafts (India) Ltd. pertains specifically to reassessment proceedings initiated under section 147 of the Act, where the AO issues a notice under section 148 and is mandated to provide reasons for reopening and dispose of the objections 8 GMEDAPADU PACS Vs. ITO filed by the assessee through

Anjaneyulu Reddy Ammireddy, Vinukonda vs. Income Tax Officer, Ward-1, Narasaraopet

ITA 542/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.542/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Vs. Anjaneyulu Reddy Ammireddy, Income Tax Officer, Vinukonda. Ward-1, Pan: Aelpa3332C Narasaraopet. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Gvn Hari, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 06/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 25/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/02/2024. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal:

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151Section 151ASection 69

under section 148A(d) of the Act, dated 08/04/2022, wherein it was held by him that it was a fit case for issuing notice under section 148 of the Act. Notice under section 148 of the Act, dated 08/04/2022, was thereafter issued by the AO. In response, the assessee filed ... under section 147 r.w.s 144B of the Act, dated 29/02/2024. Elaborating on his contention, the Ld. AR submitted that the AO had issued notice under section 148 of the Act, dated 08/04/2022, i.e., beyond the period of three years from the end of the assessment year

Ashok Rudraraju, Visakhapatnam vs. Income-Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 439/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 151(1)Section 151ASection 251(1)(a)Section 69A

possession reveals income escaping assessment of Rs.29,39,061 only. 3. The order passed under section 148A(d) dated 27.07.2022 and the notice under section 148 issued on 27.07.2022 are passed/issued respectively with the prior approval/sanction of Pr. Commissioner of Income-tax-1, Visakhapatnam as against the approval ... mandated by section 151(ii) for orders passed/notices issued beyond three years from the end of the relevant assessment year. 4. The initial notice under section 148 dated 16.04.2021 is invalid as the same was issued with the prior approval of Jt./Addl. Commissioner of Income-tax, Range-2, Visakhapatnam

Sonu Agarwal, Jaipur vs. Income Tax Officer Ward 1(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1263/JPR/2025[2016-2017]Status: DisposedITAT Jaipur19 Nov 2025AY 2016-2017

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Gaurav Awasthi, JCIT
Section 10(38)Section 139Section 147Section 148Section 148ASection 250

been paid. Consequently, case was reopened under section 147 of the IT Act, 1961 Sonu Agarwal, Jaipur. by issuing notice under section 148 of the IT Act, 1961 dated 08.04.2021 to the assessee. In compliance, the assessee filed his return of income on 21.05.2021 declaring his total income ... concluding that on the basis of material available on record, the case of the assessee is a fit case for issuance of notice under section 148 of the IT Act, 1961 for the AY 2016-17. Consequently, notice dated 26.07.2022 under section 148 of the I.T. Act, 1961 was issued

Anita Rani W/O Sh. Rajender Singh, Cheeka Guhla, Kaithal vs. Income Tax Officer, Ward-1, Kaithal

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

ITA 781/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh19 Nov 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member)

For Appellant: Shri Navdeep Monga, AdvocateFor Respondent: Shri Prem Singh, Addl. CIT, Sr. DR
Section 144Section 148Section 234ASection 250Section 69

alleged investment in an immovable property of Rs.17,64,000, reassessment proceedings were initiated. The assessee consistently submitted that she never received the notice under section 148, that the PAN mentioned in the notice was incorrect, and that she had not purchased any such property. These submissions, along with supporting ... assessee has asserted that she never purchased the alleged property, that the PAN used in the notice was incorrect, and that the notice under section 148 was never served. These are meritorious contentions which deserve adjudication on merits. 8.2 I am therefore of the considered view that