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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 Space Kraft Infrastructure (P) Ltd., Delhi vs. ACIT Central Circle-32, Delhi

In the result, assessee’s appeal is allowed

ITA 5749/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Nov 2025AY 2020-21

Bench: This Tribunal.

Section 132Section 139Section 147Section 148Section 151

Hence, the instant appeal before this Tribunal. 3. The assessee’s grievance is on account of legal ground to this effect that the notice under Section 148 of the Act was bad in law for the particular fact that the approval under Section 151 of the Act, appearing at pages

Pawan Kumar Sharma, Noida vs. Income Tax Officer, Noida

In the result, the appeal of the assessee is allowed

ITA 5952/DEL/2024[2011-12]Status: DisposedITAT Delhi12 Nov 2025AY 2011-12

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2011-12 Pawan Kumar Sharma, Vs. Income Tax Officer, E-41, Beta-1, Greater Noida, Income Tax Departmemt. Gautam Budh Nagar, Noida Uttar Pradesh Uttar Pradesh Pan: Abrps9989C (Appellant) (Respondent)

For Appellant: Shri Neeraj Mangla, CA & PraveenFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 139Section 142(1)Section 144Section 147Section 148Section 234ASection 250Section 68

assessment year 2011-12. Proceedings under Section 147 of the Act were initiated with the prior approval of the Ld. PCIT, Noida notice under section 148 of the Act dated 23.03.2018 was issued to the assessee. No compliance has been made to the notice issued under Section 148

Lalita Agarwal L/H of Late Shri Subhash Chandra Agarwal, Delhi vs. ACIT, Circle-68(1), Delhi

In the result, all the 05 appeals of the assessee are allowed in the aforesaid manner

ITA 5667/DEL/2024[2014-15]Status: DisposedITAT Delhi12 Nov 2025AY 2014-15

Bench: S. Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Piyush Kaushik, Adv. & Shri SaurabhFor Respondent: Shri Dheeraj Kumar Jaiswal, Sr. DR
Section 144Section 147Section 148

relied upon the orders of the authorities below. 4. We have carefully considered the facts narrated above in these appeals wherein the notice under section 148 was issued in the name of a deceased assessee stating his PAN Number. Further the assessment orders are also farmed in the name ... income tax department. Therefore, the order of the Ld. CIT(A) in sustaining the assessment order is not correct. The sustenance of a notice under section 148 of the Act is the foundation stone on which subsequent re-assessment proceedings are built up. To acquire the valid jurisdiction necessarily such

Lalita Agarwal L/H of Late Shri Subhas Chandra Agarwal, Delhi vs. ACIT, Circle-68(1), Delhi

In the result, all the 05 appeals of the assessee are allowed in the aforesaid manner

ITA 5666/DEL/2024[2013-14]Status: DisposedITAT Delhi12 Nov 2025AY 2013-14

Bench: S. Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Piyush Kaushik, Adv. & Shri SaurabhFor Respondent: Shri Dheeraj Kumar Jaiswal, Sr. DR
Section 144Section 147Section 148

relied upon the orders of the authorities below. 4. We have carefully considered the facts narrated above in these appeals wherein the notice under section 148 was issued in the name of a deceased assessee stating his PAN Number. Further the assessment orders are also farmed in the name ... income tax department. Therefore, the order of the Ld. CIT(A) in sustaining the assessment order is not correct. The sustenance of a notice under section 148 of the Act is the foundation stone on which subsequent re-assessment proceedings are built up. To acquire the valid jurisdiction necessarily such

Lalita Agarwal L/H of Late Shri Subhash Chandra Agarwal, Delhi vs. ACIT, Circle 68(1), Delhi

In the result, all the 05 appeals of the assessee are allowed in the aforesaid manner

ITA 5665/DEL/2024[2013-14]Status: DisposedITAT Delhi12 Nov 2025AY 2013-14

Bench: S. Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Piyush Kaushik, Adv. & Shri SaurabhFor Respondent: Shri Dheeraj Kumar Jaiswal, Sr. DR
Section 144Section 147Section 148

relied upon the orders of the authorities below. 4. We have carefully considered the facts narrated above in these appeals wherein the notice under section 148 was issued in the name of a deceased assessee stating his PAN Number. Further the assessment orders are also farmed in the name ... income tax department. Therefore, the order of the Ld. CIT(A) in sustaining the assessment order is not correct. The sustenance of a notice under section 148 of the Act is the foundation stone on which subsequent re-assessment proceedings are built up. To acquire the valid jurisdiction necessarily such

Lalita Agarwal L/H of Late Shri Subhas Chandra Agarwal, Delhi vs. ACIT, Circle-68(1), Delhi

In the result, all the 05 appeals of the assessee are allowed in the aforesaid manner

ITA 5664/DEL/2024[2012-13]Status: DisposedITAT Delhi12 Nov 2025AY 2012-13

Bench: S. Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Piyush Kaushik, Adv. & Shri SaurabhFor Respondent: Shri Dheeraj Kumar Jaiswal, Sr. DR
Section 144Section 147Section 148

relied upon the orders of the authorities below. 4. We have carefully considered the facts narrated above in these appeals wherein the notice under section 148 was issued in the name of a deceased assessee stating his PAN Number. Further the assessment orders are also farmed in the name ... income tax department. Therefore, the order of the Ld. CIT(A) in sustaining the assessment order is not correct. The sustenance of a notice under section 148 of the Act is the foundation stone on which subsequent re-assessment proceedings are built up. To acquire the valid jurisdiction necessarily such

Lalita Agarwal L/H of Late Shri Subhas Chandra Agarwal, Delhi vs. ACIT, Circle 68(1), Delhi

In the result, all the 05 appeals of the assessee are allowed in the aforesaid manner

ITA 5663/DEL/2024[2011-12]Status: DisposedITAT Delhi12 Nov 2025AY 2011-12

Bench: S. Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Piyush Kaushik, Adv. & Shri SaurabhFor Respondent: Shri Dheeraj Kumar Jaiswal, Sr. DR
Section 144Section 147Section 148

relied upon the orders of the authorities below. 4. We have carefully considered the facts narrated above in these appeals wherein the notice under section 148 was issued in the name of a deceased assessee stating his PAN Number. Further the assessment orders are also farmed in the name ... income tax department. Therefore, the order of the Ld. CIT(A) in sustaining the assessment order is not correct. The sustenance of a notice under section 148 of the Act is the foundation stone on which subsequent re-assessment proceedings are built up. To acquire the valid jurisdiction necessarily such

Income Tax Officer, Ward-1, Jind vs. Vikas Jain, Jind

In the result, the assessee succeeds in its cross-objection

ITA 838/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.838/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Income Tax Officer Shri Vikas Jain बनाम/ Ward 1 Nav Bharat Steel & General Industries Vs. Jind-126102. Indira Bazar, Jind-126102. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aeqpj-3689-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Co No. 28/Chandi/2025 [In Ita No.838/Chandi/2024) Shri Vikas Jain Income Tax Officer बनाम/ Nav Bharat Steel & General Industries Ward 1 Vs. Indira Bazar, Jind-126102. Jind-126102. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aeqpj-3689-E (Cross Objector) : (Respondent) Assessee By : Shri Suresh Gupta (Ca) – Ld. Ar Revenue By : Smt. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 01-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 11/11/2025

For Appellant: Shri Suresh Gupta (CA) – Ld. ARFor Respondent: Smt. Tarundeep Kaur (CIT) – Ld. DR
Section 147Section 148Section 151ASection 69C

From the perusal of Section 151A, it is quite evident that scheme of faceless assessment is applicable from the stage of show cause notice under Section 148 as well as 148A. Clause 3 (b) of notification dated 29.03.2022 issued under Section 151A clearly provides that scheme would be applicable ... notice under Section 148. Even otherwise, it is a settled proposition of law that assessment proceedings commence from the stage of issuance of show cause notice. The object of introduction of faceless assessment would be defeated if show cause notice under Section 148 is issued by Jurisdictional Assessing Officer

Shri Rushabhdev Swetambar Murtipujak Jain Sangh, Ahmedabad vs. The ITO, Ward-2 (Exemption), Ahmedabad

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

ITA 136/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad11 Nov 2025AY 2012-13

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri R P Rastogi, CITDR
Section 12ASection 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

assessment within the meaning of section 147 of the Act. After obtaining the necessary approval from the Commissioner of Income Tax (Exemption), a notice under section 148 dated 27.03.2019 was issued to the assessee in the name of Rushabhdev Swetamber Murt Ipujak with PAN AAATR2081G. Despite issuance of notices under ... subsequent returns of income had been filed only under the new PAN. The assessee argued that the Assessing Officer, having issued the notice under section 148 on the surrendered PAN, had assumed jurisdiction over a non-existent and invalid PAN, rendering the reassessment Shri Rushabhdev Swetambar Murtipujak Jain Sanghvs.ITO

Bilal Kasam Memon, Pune vs. ITO, Ward 6(3), Pune

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

ITA 1281/PUN/2025[2017-18]Status: DisposedITAT Pune11 Nov 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No.1281/Pun/2025 धििाारण वर्ा /Assessment Year: 2017-18 Bilal Kasam Memon, Ito, Ward-6(3), Pune Memon Manzil 451/3, Salisbury Park, Gultekdi, Pune-411037 Vs. Maharashtra Pan-Adhpm5491R अपीलार्थी / Appellant प्रत्यर्थी/Respondent

For Appellant: Shri Sachin Kumar (virtually)For Respondent: Shri Uodol Raj Singh, DR
Section 139Section 147Section 148Section 250Section 69B

transactions during the period under consideration . Therefore the case of the 3 assessee was reopened under section 147 of the IT act and notice under section 148 and 142 (1) of the IT act respectively were issued to the assessee . In response to notice under section 148

Kakoli Debanshi, Birbhum vs. ITO, Ward 3(1), Suri

In the result, the appeal of the assessee is allowed

ITA 1664/KOL/2025[2015-2016]Status: DisposedITAT Kolkata11 Nov 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm**

Section 142(1)Section 144Section 147Section 148

## **IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH, KOLKATA** # **BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

Vikash Mimani, Sikkim vs. A.C.I.T., Circle - 3(2), Gangtok

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 1409/KOL/2025[2017-2018]Status: DisposedITAT Kolkata11 Nov 2025AY 2017-2018

Bench: the Tribunal. An affidavit explaining the reasons for such delay has been filed. We, after considering the contents of the affidavit and submissions of both sides, we are satisfied that the delay was due to reasonable cause and the same is condoned.

Section 142(1)Section 144Section 147Section 148Section 249(4)(b)

assessee. Consequently, after obtaining necessary approval, proceedings under Section 147 of the Income-tax Act, 1961 (hereafter “the Act”) were initiated, and notice under Section 148 was issued requiring the assessee to file the return within 30 days. As there was no compliance, notice under Section

Vikash Mimani, Sikkim vs. I.T.O., Ward - 3(1), Gangtok

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 1408/KOL/2025[2016-2017]Status: DisposedITAT Kolkata11 Nov 2025AY 2016-2017

Bench: the Tribunal. An affidavit explaining the reasons for such delay has been filed. We, after considering the contents of the affidavit and submissions of both sides, we are satisfied that the delay was due to reasonable cause and the same is condoned.

Section 142(1)Section 144Section 147Section 148Section 249(4)(b)

assessee. Consequently, after obtaining necessary approval, proceedings under Section 147 of the Income-tax Act, 1961 (hereafter “the Act”) were initiated, and notice under Section 148 was issued requiring the assessee to file the return within 30 days. As there was no compliance, notice under Section

Thiruvarur Lions Eye Hospital Trust, Thiruvarur vs. Income Tax Officer, Thiruvarur

In the result, both the appeals filed by the assessee are allowed

ITA 2535/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Nov 2025AY 2018-19

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2531 & 2535/Chny/2025 िनधा"रण वष"/Assessment Years: 2016-17 & 2018-19 M/S. Thiruvarur Lions Eye The Income Tax Officer, Hospital Trust, Vs. Thiruvarur 157, Vandampalai, Kangalanchery Post, Thiruvarur – 610 101. Pan: Aaatt 0632P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri D. Ambarish, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

For Appellant: Shri D. Ambarish, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 10Section 139Section 143(3)Section 147Section 148Section 250Section 272A(2)(e)

under section 11; non-filing attracts penalty. 10. The Ld. DR further submits that the filing of the return only after issuance of notice under section 148 does not absolve or cure the default. The statutory obligation to furnish a return within the prescribed time is independent of the assessment

Thiruvarur Lions Eye Hospital Trust, Thiruvarur vs. Income Tax Officer, Thiruvarur

In the result, both the appeals filed by the assessee are allowed

ITA 2531/CHNY/2025[2016-17]Status: DisposedITAT Chennai11 Nov 2025AY 2016-17

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2531 & 2535/Chny/2025 िनधा"रण वष"/Assessment Years: 2016-17 & 2018-19 M/S. Thiruvarur Lions Eye The Income Tax Officer, Hospital Trust, Vs. Thiruvarur 157, Vandampalai, Kangalanchery Post, Thiruvarur – 610 101. Pan: Aaatt 0632P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri D. Ambarish, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

For Appellant: Shri D. Ambarish, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 10Section 139Section 143(3)Section 147Section 148Section 250Section 272A(2)(e)

under section 11; non-filing attracts penalty. 10. The Ld. DR further submits that the filing of the return only after issuance of notice under section 148 does not absolve or cure the default. The statutory obligation to furnish a return within the prescribed time is independent of the assessment

Income Tax Officer 17(1)(1), Mumbai vs. Ashok Amritlal Nayak, Mumbai

In the result, appeal of the revenue is dismissed and the C

ITA 3484/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Surendra Mohan, Sr. DRFor Respondent: Shri Rahul Hakani, AR
Section 115BSection 143(1)Section 148Section 151ASection 250Section 68

filed by the assessee. 4. We heard the parties and perused the material on record. The ld. AR submitted that the notice under section 148 which is dated 12.04.2022 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. The ld. DR rebutted the said argument stating that the AO initiated the proceedings by issue of notice

Lumar Gems, Mumbai vs. ACIT Circle 23(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 3450/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr. DR
Section 147Section 148Section 148ASection 151Section 250Section 68Section 69C

admit the additional grounds. 4. We heard the parties and perused the material on record. The ld. AR submitted that the notice under section 148 dated 20.04.2022 is beyond the period of 3 years and therefore as per the provisions of Section 151 of the Act the AO should have ... 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. The ld. DR rebutted the said argument stating that the AO initiated the proceedings by issue of notice

Prajesh Maneklal Rupareliya, Mumbai vs. 33(1)(1), Mumbai

In the result, the ground No

ITA 6608/MUM/2024[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 115BSection 132(4)Section 139(1)Section 143(3)Section 147Section 148Section 151Section 254(1)Section 69A

them is Vagabond Tradex Pvt. Ltd. Thus, in order to verify the transaction, the case of assessee was reopened. The notice under section 148 dated 13.04.2025 was issued. In response to notice under section 148, the assessee filed return of income on 24.05.2022 declaring same income as declared in income ... copy of all materials and information which was basis of taking view about escapement of income as well as necessary approval for issuing notice under section 148. No information is provided to the assessee. The assessment was completed without providing required details and evidences. Copy of approval under section

Khurshid Ahmad Dar, Jammu and Kashmir, India vs. ITO Ward, Udhampur

In the result, the appeal of the assessee is allowed

ITA 236/ASR/2025[2017-18]Status: DisposedITAT Amritsar10 Nov 2025AY 2017-18

Bench: Dr. Mitha Lalmeena, Hon'Ble & Shri Udayan Das Gupta, Hon'Blekhurshid Ahmad Dar Vs. Ito, Ward, Nully Poshwari Turkawangam, Udhampur Shopia, 192305, Jammu & Kashmir, India.Pin 192305. Pan No. Awmpd5664K Assessee By Shri Rohit Kapoor, Adv. & Shri V.S. Aggarwal, Itp. Revenue By Mrs. Roshanta Kumari Meena, Cit Dr. Date Of Hearing 23.09.2025. Date Of Pronouncement To. [1 .2025. Order Dr. Mitha Lal Meena, A.M.:

Section 144Section 147Section 148Section 148ASection 151Section 151(1)Section 250Section 250(6)Section 282Section 69A

under Section 69A of the Income Tax Act, 1961. 2. That the assessment framed under section 147 is bad in law as the notice under section 148 was issued on 13.04.2021 without adhering to the new procedure applicable from 01.04.2021, specifically without complying with the provisions of section 148A ... legal issue raised by the assessee is that the assessment framed under section 147 is bad in law as the notice under section 148 was issued on 13.04.2021 without adheringto the new procedure applicable from 01.04.2021, specifically without complying with the provisions of section 148A. 5. We have heard both

Shri Shailender Vaid, Jammu vs. Deputy Commissioner of Income Tax, Circle-1, Jammu

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

ITA 118/ASR/2025[2011-12]Status: DisposedITAT Amritsar10 Nov 2025AY 2011-12

Bench: Dr. Mitha Lalmeena, Hon'Ble & Shri Udayan Das Gupta, Hon'Bledeputy Commissioner Of Income- Shailender Vaid, Vs. House No. 179-P, Sector-3, Tax, Circle-L, Jammu (J&K) Trikuta Nagar, Jammu (J & K) Pan No. Aawpv6431C Assessee By Shri Joginder Singh, Ca Shri Charan Dass, Sr. Dr Revenue By Date Of Hearing 24.09.2025. Ft . // .2025. Date Of Pronouncement

Section 124Section 142(1)Section 143(2)Section 144Section 147Section 148Section 68

distinguish. 9. Admittedly in the present case, the reasons for reopening have been recorded by the ITO Ward 1(3), Jammu and that notice under section 148 is also issued by the ITO, Ward 1(3), Jammu to initiate the re-assessment proceedings besides notices u/s 142(1) and show