“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

Kamlawati Chowhan, Howrah vs. ITO, Ward 46(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1247/KOL/2025[2018-19]Status: DisposedITAT Kolkata27 Oct 2025AY 2018-19

Bench: the CIT(A). However, due to non-compliance on consecutive dates, the CIT(A) dismissed the appeal ex parte. The assessee has now preferred the present appeal before the Tribunal, contending that the authorities below passed the orders without affording a reasonable opportunity to substantiate its claim with supporting evidence. The assessee, therefore, prayed that one more opportunity may be granted to substantiate its case before the Assessing Officer.

Section 131Section 148Section 148ASection 250Section 69C

compliance by the assessee to the show cause notice issued under Section 148A(b), an order under Section 148A(d) was passed and notice under Section 148 of the Act was issued thereafter. In response, the assessee filed its return of income declaring the same total 2 Kamlawati Chowhan income

Pramod Lakra, Deputy Commissioner of Income Tax, Circle 11(1), Kolkata vs. M/S. Dalmia Impex Private Limited, Kolkata

In the result the Cross Objection No

ITA 2544/KOL/2024[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 143(3)Section 148Section 148A

33/Kol/2025 M/s Dalmia Impex Private Limited 4. At the outset, the Ld. Counsel for the assessee submitted that the reassessment notice under section 148 was issued on 26.06.2021 under the old regime. As per the judgment of the Hon’ble Supreme Court in Union of India v. Rajesh Bansal ... after adjusting the remaining four days available within limitation as per Rajesh Bansal (supra), the last permissible date for issuance of a valid notice under section 148 would have been 15.06.2022. However, the Assessing Officer issued the fresh notice under section 148A(d) only on 29.07.2022, which is clearly beyond

ITO, Ward 10(2), Kolkata vs. Alex Tradecom Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2198/KOL/2024[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2197 & 2198/Kol/2024 Assessment Years: 2013-14 & 2014-15 Ito, Ward-10(2), Kolkata…………..…………………………….…….……Appellant Vs. Alex Tradecom Pvt. Ltd…………..……………….………...……...…..…..Respondent 4, Ratan Sarkar Garden Street, Burrabazar, Kol- 700069. [Pan: Aajca6146P] Appearances By: Smt. Madhumita Das, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Akshay Ringasia, Ca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Revenue For The Assessment Years 2013-14 & 2014-15 Against Separate Orders Dated 05.08.2024 & 26.07.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. Both The Appeals Have Been Filed By The Revenue With Delays Of 38 Days. The Revenue Has Filed Separate Affidavits For Condonation Of The Delays. After Considering The Reasons Cited In The Affidavits For Condonation Of Delay, We Find That The Reasons Are Valid And

Section 148Section 148ASection 250

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

ITO, Ward-10(2), Kolkata vs. Alex Tradecom Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2197/KOL/2024[2013-14]Status: DisposedITAT Kolkata27 Oct 2025AY 2013-14

Section 148Section 148ASection 250

Sri Ramalingam Radha, Namakkal vs. ACIT, Circl-I, Erode

ITA 2342/CHNY/2025[2013-14]Status: DisposedITAT Chennai27 Oct 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2342/Chny/2025 निर्धारण वर्ष/Assessment Year: 2013-14 Sri Ramalingam Radha, Oa-13, Kumaresapuram, 7Th Street, Rajiv Nagar, Tiruchengode, Namakkal-637 211. [Pan: Accpr 2234 H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से / Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. The Acit, Circle-1, Erode. (प्रत्यर्थी/Respondent) : Mr.R. Venkata Raman, Fca : Mr.Krishna Murthy At, Jcit : 22.10.2025 : 27.10.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 26.06.2025 For Ay 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. Learned Commissioner Of Income Tax (Appeals) Is Not Justified In Dismissing The Appeal, On The Ground That The Assessee Did Not Respond To Three Notices Issued. 2. Learned Commissioner Of Income Tax Tax (Appeals) Ought Not To Have Relied On A Few Decisions Rendered Under Other Acts & On A Few Under The Income Tax Act, None Of Which Apply To The Facts Of The Assessee'S Case. :: 2 ::

Section 144BSection 147Section 148

settled the law under Article 141 of the Constitution of India and laid down that only FAO would have the jurisdiction to issue notices under Section 148 of the Act. 4. He states that though this Court has held conversely, that both JAO and FAO would have the concurrent jurisdiction

Pichaimani Gunasundari, Kancheepuram vs. ITO, Nc-22(1), Tambaram

In the result, appeal filed by the assessee is allowed in terms above

ITA 2333/CHNY/2025[2019-20 ]Status: DisposedITAT Chennai27 Oct 2025

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2333/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 V. Pichaimani Gunasundari, The Ito, No.65, Saratha Flats, Non-Corporate Ward-22(1), Ganapathi Nagar, Tambaram. 4Th Street, Urapakkam, Kancheepuram-603 210. [Pan: Cqgpg 6518 M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.N. Arjunraj, AdvocateFor Respondent: Mr.Krishna Murthy AT, JCIT

Section 147Section 148Section 148ASection 250(6)Section 69Section 69A

prescription of law / procedure in relation thereto and hence ought to have appreciated that in the absence of valid foundation for issuance of notice under Section 148 of the Act in view of issuance of such notice by JAO instead of FAO, the consequential re- assessment should be considered ... clear that the respondents have erred in not following the mandatory faceless procedure as prescribed in the scheme dated 29.03.2022. Since notices under Section 148 of the Act were not issued in a faceless manner, the entire further proceeding founded upon it and assessment orders stand vitiated. Thus, the impugned

Nmc Industries Pvt Ltd, Mumbai vs. JCIT (OSD) CC2(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5215/MUM/2025[2010-11]Status: DisposedITAT Mumbai27 Oct 2025AY 2010-11

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 143(3)Section 147Section 148Section 271(1)(c)

Maharashtra, wherein certain dealers were identified as hawala operators providing accommodation bills, the Assessing Officer reopened the case under section 147 and issued notice under section 148. 4. During reassessment proceedings, the Assessing Officer noted that the assessee had made purchases from eight such parties alleged to be non-genuine

Income Tax Officer-41(2)(4), Mumbai, Bkc vs. Rbi Employees Bhagvati Coop Housing Society Ltd, Mulund East, Mumbai

ITA 4073/MUM/2025[2011]Status: DisposedITAT Mumbai27 Oct 2025

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Fenil BhattFor Respondent: Shri Annavaran Kosuri

Section 139Section 143(3)Section 147Section 148Section 2(47)(v)Section 271(1)(c)Section 48Section 50CSection 53A

fact that the assessee had not filed any return of income voluntarily under section 139 and only filed a return in response to notice under section 148, which indicated prima facie Concealment of taxable income and warranted addition based on available the materials with the Assessing Officer.” 3. The relevant

Income Tax Officer-41(2)(4), Mumbai, Kautilya Bhavan, Bkc vs. Rbi Employees Bhagvati Co-Op Housing Society Ltd., Mulund East, Mumbai

ITA 3595/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Oct 2025AY 2011-12

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Fenil BhattFor Respondent: Shri Annavaran Kosuri

Section 139Section 143(3)Section 147Section 148Section 2(47)(v)Section 271(1)(c)Section 48Section 50CSection 53A

Sachin Shrikant Naik, Santacruz East, Mumbai vs. Dy. Commissioner of Income Tax - 42(3)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2183/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Oct 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2015-16

For Appellant: Mr. Dhiraj S. DandgavalFor Respondent: 03/09/2025

Section 69A

escaped assessment, and accordingly income chargeable to tax had escaped assessment, and accordingly income chargeable to tax had escaped assessment, and accordingly issued notice under section 148 of the Act on 29t issued notice under section 148 of the Act on 29th March, 2017. h March, 2017. 2.3 In response

Deputy Commissioner of Income Tax, Central Circle-15, Delhi vs. Divyansh Infracon Private Limited, Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 543/DEL/2025[2012-13]Status: DisposedITAT Delhi27 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

For Appellant: Shri V.K. Sabharwal, AdvFor Respondent: Ms. Pooja Swaroop, CIT- DR

Section 148Section 149Section 153ASection 153C

because of reference to word " at that time". In simpler words, the proviso to section 149 of the Act states that no notice under section 148 shall be issued at any time in a case for the relevant assessment year beginning on or before 1st day of April ... notice under section 148 or section 153A or section 153C could not have been issued at that time on account of being beyond the time limit specified under the provisions of clause (b) of sub-section (1) of this section or section 153A or section 153C, as the case

Deputy Commissioner of Income Tax, Central Circle-15, Delhi vs. Divyansh Infracon Private Limited, Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 538/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Oct 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

For Appellant: Shri V.K. Sabharwal, AdvFor Respondent: Ms. Pooja Swaroop, CIT- DR

Section 148Section 149Section 153ASection 153C

Meena Jain, Gurgaon vs. ITO Ward-53(92), Gurgaon

In the result, the appeal is allowed

ITA 4072/DEL/2025[2015-16]Status: DisposedITAT Delhi27 Oct 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singhassessment Year: 2015-16 Mrs. Meena Jain, Vs. Income Tax Officer, B-702, Rail Vihar Apartments, Ward-53(92), Sector 15, Gurugram Gurugram Pin: 122 001 Haryana Pan :Aahpj3007B (Appellant) (Respondent)

Section 139Section 139(1)Section 148Section 250Section 271F

amount of income of Rs.1,90,110/- as declared in the return of income filed by her on 03.05.2022 in response to the notice under Section 148 of the Act dated 04.04.4022. The assessee also submitted that the details of credit card expenditure as well as the property purchased

Flint Power Tools (P) Ltd, Gurugram vs. ACIT, Central Circle-1, Faridabad

In the result, the appeal of the assessee is allowed

ITA 5642/DEL/2024[2019-20]Status: DisposedITAT Delhi27 Oct 2025AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2019-20 M/S. Flint Power Tools (P) Vs. Assistant Commissioner Of Ltd., Income Tax, Plot Nos. 594, 595, Central Circle-1, Sector 8 Imt Manesar, Faridabad-I, New-1 Gurugram, Haryana Pan: Aadcn0078K (Appellant) (Respondent)

For Appellant: Shri Lalit Mohan, CA & Shri AnkitFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 132Section 142(1)Section 147Section 148Section 151Section 151ASection 250(6)Section 37

PCIT, Gurugram vide order dated 23.12.2022. The case of the assessee was re-opened with prior approval of Ld. PCIT, Gurugram. Accordingly, notice under Section 148 of the Act was issued and served upon the assessee on 26.03.2023. In response to this notice, the assessee filed its ITR, declaring income ... circular/notification 5 dated 29.03.2022 of the CBDT, wherein, it has been specifically enumerated that the NFAC has exclusive power to issue the notice under Section 148 of the Act, 1961. 6. A Co-ordinate Bench of this Court in Jatinder Singh Bhangu's case (supra) and Jasjit Singh's case

Goodone Traders Private Limited, Delhi vs. CIT(A), Delhi

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

ITA 5591/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Oct 2025AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2014-15 Goodone Traders Private Vs. Commissioner Of Income Tax Limited, 886A/47 (Appeals), Ward No. 6, Mehrauli Delhi Delhi- 1100 30 Pan: Aaacy2998Q (Appellant) (Respondent)

For Appellant: Ms. Meenal Goyal, CA, Ms. VidhiFor Respondent: Shri Sanjeev Kaushal, CIT (DR)

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

income of Rs.563,71,92,774/- has escaped assessment within the meaning of section 147 of the Act and the notice under Section 148 of the Act was issued on 30.06.2021. Against notice under Section 148 of the Act, the 2 assessee filed writ petition, challenging validity of notice under ... disposed of writ petition in Civil Appeal No.3005/2022 dated 04.05.2022 in the case of Union of India vs. Ashish Agarwal and many others. Notice under Section 148 of the Act was issued on 25.07.2022. Notice under Section 143(2) of the Act dated

Income Tax Officer, Income Tax Office vs. Ritu Bala, Faridabda

In the result, the appeal of Revenue is dismissed

ITA 3621/DEL/2024[2018-19]Status: DisposedITAT Delhi27 Oct 2025AY 2018-19

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2018-19 Income Tax Officer, Ritu Bala, Vs. Faridabad 4237 Indra Prashtha Colony, Haryana Faridabad – 121 001 Haryana Pan :Bdhpb1495B (Appellant) (Respondent)

Section 142(1)Section 144Section 144BSection 148Section 148ASection 250Section 250(4)Section 69C

that as per order under Section 148A(d) of the Act dated 31.03.2022 was passed with approval of specified authority along with notice under Section 148 of the Act. In case of assessee, specific information was flagged as per Risk Management Strategy formulated by the CBDT under clause ... violation of rule 46A and therefore the order of CITI) needs to be set aside." 5. Learned Authorized Representative for Revenue submitted that notice under section 148 in this case was issued to the assessee on 31.03.2022 requiring 4 ITA No. 3621/Del.2024 to furnish, within 30 days from service

ACIT, CC- 15, New Delhi vs. Saloni Narang, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1496/DEL/2018[2012-13]Status: DisposedITAT Delhi27 Oct 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2012-13] Asst. Commissioner Of Income Saloni Narang, Tax, Central Circle-15, 5, Dr. G.G. Narang Marg, Room No.353, E-2, Ara Vs Cavalary Lane, Centre, Jhandewalan Ext. Delhi-110007 New Delhi-110055 Pan-Aafpn2692C Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv. & Shri Somil Agarwal, Adv. Revenue By Ms. Rajinder Kaur, Cit-Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 27.10.2025

Section 132Section 143(3)Section 153Section 153ASection 153DSection 69A

case may be, being satisfied on the reasons recorded by the Assessing Officer about fitness of a case for the issue of notice under Section 148, need not issue such notice himself." 15. A plain reading of the aforesaid provision would indicate that Section 151 of the Act stipulates that ... does not mention any reason for coming to the conclusion that it is a fit case for the issue of a notice under Section 148. We are also of the opinion that the Commissioner has mechanically accorded permission. He did not himself record that he was satisfied that this

Deputy Commissioner of Income Tax, Jalgaon vs. Taradevi Ratanlal Bafna, Jalgaon

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

ITA 499/PUN/2025[2018-19]Status: DisposedITAT Pune24 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

For Appellant: S/Shri Suchek Anchaliya and Tushar NagoriFor Respondent: Shri Amit Bobde, CIT

Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 148ASection 68Section 69C

order disposing the objections of the assessee was passed on 04.04.2022 under section 148A(d) of the Act. The AO issued notice under section 148 dated 04.04.2022. On perusal of the order under section 148A(d) of the Act and 148 (page ... issued within three years since as per the 5th proviso to section 149, the AO has got additional 9 days for issue of notice under section 148 i.e. upto 09.04.2022. since the extended time of 9 days i.e. from 22.03.2022 to 31.03.2022 was given to the assessee. Therefore

Manorama Patwa, Howrah vs. I.T.O., Ward - 47(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 493/KOL/2025[2015-2016]Status: DisposedITAT Kolkata24 Oct 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubeyshri Rakesh Mishra & Assessment Year: 2015-16 Manorama Patwa…..………….……………………….……….……….……Appellant Shree Shyam Garden – 5Gh, 12, Haradutta Ray Chamaria Road, Howrah-711101.. [Pan: Aunpp4730F] Vs. Ito, Ward-47(1), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri A. Kochar, Ar, Appeared On Behalf Of The Appellant. Shri Arun Kr. Meena, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 21, 2025 Date Of Pronouncing The Order : October 24, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 04.02.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 144Section 148Section 148ASection 250Section 68

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

Bakiavathy Raghupathy, Tiruvarur vs. ITO, Ward-1, Tiruvarur

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

ITA 2325/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2325/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Bakiavathy Raghupathy, Vs. The Income Tax Officer, No. 43, Ayyanar Koil Street, Tiruvarur, Ward 1, Atp District 610 001, Tiruvarur. Tamil Nadu. [Pan: Aafpr7084Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Hitesh, Advocate ""थ" की ओर से/Respondent By : Shri C.P. Solomon, Jcit सुनवाई की तारीख/ Date Of Hearing : 23.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 01.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. In The Grounds Of Appeal, Besides Challenging Assumption Of Jurisdiction Under Section 147 Of The Income Tax Act, 1961 [“Act” In Short], On Merits, The Assessee Also Challenged Confirmation Of Addition

For Appellant: Shri Hitesh, AdvocateFor Respondent: Shri C.P. Solomon, JCIT

Section 147Section 148Section 148A

confirmed the order of the Assessing Officer. 4. The ld. AR Shri Hitesh, Advocate drew our attention to the notice under section 148 of the Act dated 05.04.2022, placed on record and submits that the Jurisdiction Assessing Officer issued the above said notice, whereas, the assessment under section 147 r.w.s ... r.w.s. 144 r.w.s. 144B of the Act dated 31.01.2024 was passed by the assessment unit of NFAC. Further, we note that the notice under section 148 of the Act dated 05.04.2022 was issued by the Jurisdictional Assessing Officer. On perusal of the decision of the Hon’ble High Court