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“service of notice”

ReassessmentSection 148Section 1483,297 judgments

ANILKUMAR RAMANBHAI AMIN,VADODARA vs. INCOME TAX OFFICER, VADODARA

The appeal of the assessee is allowed for statistical purposes

ITA 2417/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2012-13

Bench: Ms. Suchitra Kamble

For Appellant: Respondent by : Shri Girish Parihar, Sr. D.RFor Respondent: Shri Girish Parihar, Sr. D.R
Section 143(3)Section 148Section 69A

under: “1. The learned CIT(A) erred in law and on facts in dismissing the appeal ex-parte without effecting proper and valid service of notice upon the appellant. The appellate proceedings were concluded without ensuring that notice was actually delivered to the appellant at his correct communication address ... thereby violating the principles of natural justice. 3. The impugned appellate order is invalid and bad in law, having been passed without proper service of notice and without fulfilling the jurisdictional requirement of valid communication. In the absence of legally sustainable service, the entire ex-parte order stands vitiated

TRAMBAK RAGHUNATH KALE,AMRAVATI vs. INCOME TAX OFFICER WARD 3, AMRAVATI, AMRAVATI

In the result, appeal is dismissed

ITA 30/NAG/2026[2020-2021]Status: DisposedITAT Nagpur26 Mar 2026AY 2020-2021

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.30/Nag/2026 Assessment Year : 2020-21 Trambak Raghunath Kale, Vs. Income Tax Officer, Congress Nagar, Camp Road, Ward-3, Amravati Amravati-444602, Maharashtra Pan: Bbbpk6461L Appellant Respondent

For Appellant: NoneFor Respondent: Shri Surjit Kumar Saha
Section 143(3)Section 250(6)

Income Tax Act, 1961 (in short ‘the Act’). 2. When the case called for, none appeared on behalf of the assessee despite due service of notice of hearing. I therefore proceed to adjudicate the appeal with the assistance of ld. Departmental Representative and available material on record exparte qua assessee

ITO, AHMEDABAD vs. UDAYAN MANDAVIA, AHMEDABAD

In the result, the appeal filed by the Department is dismissed

ITA 154/AHD/2026[2017-18]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Sudhakar Verma, Sr. DRFor Respondent: Shri Palak Pavagadhi, AR
Section 115BSection 144BSection 147Section 154Section 69A

from 30% to 60% was beyond the scope of section 154. The Ld. CIT(A) also took note of the submissions regarding non-service of notice and violation of principles of natural justice. In view of these findings, the Ld. CIT(A) quashed the rectification order passed under section

ARHAM ANMOL PROJECTS PRIVATE LIMITED,VILLAGE VALSHIND, BHIWANDI vs. CIRCLE 1 KALYAN, KALYAN, THANE

In the result, the legal grounds challenging the validity of the assessment are dismissed

ITA 5011/MUM/2025[2019-20]Status: DisposedITAT Mumbai26 Mar 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararham Anmol Projects Dcit Circle 1, Private Limited 2Nd Floor, Rani H. No. 1113, Ground Vs. Mansion, Murbad Floor, Arham Logiparc, Road, Kalyan Nh-3, Nashik Highway, (West), Thane, Village Valshind, Maharashtra – 421 Bhiwandi, Maharashtra – 301 421 302. Pan/Gir No. Aagca9644P (Applicant) (Respondent) Assessee By Shri Subhash Bains, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 26.03.2026

Section 144Section 144BSection 147Section 148Section 194CSection 194ISection 234FSection 250

deeming fiction under section 292BB, according to the learned Authorised 9 Arham Anmol Projects Private Limited Representative, applies only to defects in service of notice and not to cases where the statutory requirement of valid issuance by the competent authority is not satisfied. It was therefore contended that ... competent Jurisdictional Assessing Officer, the argument of complete absence of notice does not survive. The provisions of section 292BB, which cure defects in service of notice, do not even arise for consideration in a situation where the notice itself stands issued. 26. Evaluating the issue across different assessment regimes, whether

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 142/RPR/2026[2014-15]Status: DisposedITAT Raipur24 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

already been made explicit in the aforementioned decisions of the Allahabad High Court. That provision would apply in so far as failure of 'service‟ of notice was concerned and not with regard to failure to „issue‟ notice. In other words, the failure of the Assessing Officer, in reassessment proceedings ... available on record. On perusal of the record, it is noted that the department has failed to produce any proof as regards the service of notice u/s.143(2) of the Act. It is settled legal position that the issuance of notice u/s.143(2) is sine-qua-non for framing

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

ITA 141/RPR/2026[2013-14]Status: DisposedITAT Raipur24 Mar 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

For Appellant: S/shri Yash Dhariwal &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143Section 143(2)Section 143(3)Section 148

already been made explicit in the aforementioned decisions of the Allahabad High Court. That provision would apply in so far as failure of 'service‟ of notice was concerned and not with regard to failure to „issue‟ notice. In other words, the failure of the Assessing Officer, in reassessment proceedings ... available on record. On perusal of the record, it is noted that the department has failed to produce any proof as regards the service of notice u/s.143(2) of the Act. It is settled legal position that the issuance of notice u/s.143(2) is sine-qua-non for framing

VIJAY KOTHARI,INDORE vs. DCIT (CENTRAL)-1, INDORE

ITA 267/IND/2024[2015-16]Status: DisposedITAT Indore20 Mar 2026AY 2015-16
Section 143(3)Section 250

nhas re-produced the written-submission filed by assessee before him, the\nbench directed Ld. AR to file a detailed explanation qua the service of notices\nof hearing and impugned order by CIT(A). Pursuant to direction of bench, the\nLd. AR filed following Chart giving complete details

PRAJYOTH KUMAR ADI,HYDERABAD vs. ITO, WARD-4(1), HYDERABAD

In the result, both the appeals filed by the assessee are allowed for statistical purposes in terms of our aforesaid observations

ITA 2077/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Mar 2026AY 2020-21

Bench: us: “1. On the facts and in the circumstances of the case, the order of the Id. CIT(A) is erroneous both on facts and in law, and is passed in gross violations of principles of natural justice.

Section 142(1)Section 144Section 147Section 148Section 148ASection 270A

Learned Authorized Representatives of both parties. In our view, as the CIT(A) office had failed to carry out a valid service of notice intimating the fixation of the appeal by not forwarding/dropping the same in the email account provided by the assessee in Form-35 ie., padi.kumar@gmail.com, therefore

NARAYAN BARTER PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER,WARD-6(1),KOLKATA, KOLKATA

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

ITA 2572/KOL/2025[2011-12]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 68

sections, being sections 147, 148 and 149 in the 1961 Act. A clear distinction has been made out between 'issue of notice' and 'service of notice' under the 1961 Act. Section 149 prescribes the period of limitation. It categorically prescribes that no notice under section 148 shall be issued after ... prescribed limitation has lapsed. Section 148(1) provides for ITA No(s). 2572/KOL/2025 Assessment Year(s) 2011-12 Narayan Barter Private Limited. service of notice as a condition precedent to making the order of assessment. Once a notice is issued within the period of limitations, jurisdiction becomes vested

MAHESH PRAKASH BENDE,MUMBAI vs. INCOME TAX OFFICER CIRCLE 27(2), MUMBAI

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

ITA 8028/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Mar 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarmahesh Prakash Ito Circle - 27(2), Bende 4Th Floor, Tower No. 6, 302, 3Rd Floor, Prithvi Vs. It Office, Vashi Park, Sector-30, Vashi Railway Station Navi Mumbai-400 075 Building, Navi Mubmai – 400 703 Pan/Gir No. Alnpb2531M (Applicant) (Respondent) Assessee By Shri Devendra Jain, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 25.02.2026 Date Of Pronouncement 20.03.2026

Section 142(1)Section 144Section 144BSection 147Section 148Section 151Section 249Section 249(3)Section 250

were issued calling for details. The case was transferred to the National Faceless Assessment Centre under the Faceless Assessment Scheme, 2019. Despite service of notices, including through the Verification Unit, no response was received from the assessee. Thereafter, a final opportunity was granted by issuing notice under section 144, which

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7844/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties\nalong with all the supporting documents in the physical form\nbefore the AO.\n3. Non service of notice/ summon to supplier cannot be a ground for\nmaking the addition\nWith regard to remarks made by the AO that summons issued to\nvarious ... purchases made by it were bogus.\nIn the case of Nikunj Exim Export, the Hon'ble Bombay\nHigh Court has held that non service of notice does not\nconclusively prove the non genuineness of a\ntransacttion. By producing various documents the\nassessee had proved that balance of convenience

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7843/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties\nalong with all the supporting documents in the physical form\nbefore the AO.\n3. Non service of notice/ summon to supplier cannot be a ground for\nmaking the addition\nWith regard to remarks made by the AO that summons issued to\nvarious ... purchases made by it were bogus.\nIn the case of Nikunj Exim Export, the Hon'ble Bombay\nHigh Court has held that non service of notice does not\nconclusively prove the non genuineness of a\ntransacttion. By producing various documents the\nassessee had proved that balance of convenience

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties along with all the supporting documents in the physical form before the AO. 3. Non service of notice/ summon to supplier cannot be a ground for 3. 3. 3. Non service of notice/ summon to supplier cannot be a ground ... service of notice/ summon to supplier cannot be a ground for Non service of notice/ summon to supplier cannot be a ground for making the addition making the addition making the addition making the addition With regard to remarks made by the AO that summons issued to various purchase parties

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7841/DEL/2025[2021-22]Status: DisposedITAT Delhi20 Mar 2026AY 2021-22
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties\nalong with all the supporting documents in the physical form\nbefore the AO.\n3. Non service of notice/ summon to supplier cannot be a ground for\nmaking the addition\nWith regard to remarks made by the AO that summons issued to\nvarious ... purchases made by it were bogus.\nIn the case of Nikunj Exim Export, the Hon'ble Bombay\nHigh Court has held that non service of notice does not\nconclusively prove the non genuineness of a\ntransacttion. By producing various documents the\nassessee had proved that balance of convenience

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties along with all the supporting documents in the physical form before the AO. 3. Non service of notice/ summon to supplier cannot be a ground for 3. 3. 3. Non service of notice/ summon to supplier cannot be a ground ... service of notice/ summon to supplier cannot be a ground for Non service of notice/ summon to supplier cannot be a ground for making the addition making the addition making the addition making the addition With regard to remarks made by the AO that summons issued to various purchase parties

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7839/DEL/2025[2019-20]Status: DisposedITAT Delhi20 Mar 2026AY 2019-20
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties\nalong with all the supporting documents in the physical form\nbefore the AO.\n3. Non service of notice/ summon to supplier cannot be a ground for\nmaking the addition\nWith regard to remarks made by the AO that summons issued to\nvarious ... purchases made by it were bogus.\nIn the case of Nikunj Exim Export, the Hon'ble Bombay\nHigh Court has held that non service of notice does not\nconclusively prove the non genuineness of a\ntransacttion. By producing various documents the\nassessee had proved that balance of convenience

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7838/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Mar 2026AY 2018-19
For Appellant: Shri Amit Goel andFor Respondent: Ms. Monika Singh, CIT-DR
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties\nalong with all the supporting documents in the physical form\nbefore the AO.\n3. Non service of notice/ summon to supplier cannot be a ground for\nmaking the addition\nWith regard to remarks made by the AO that summons issued to\nvarious ... purchases made by it were bogus.\nIn the case of Nikunj Exim Export, the Hon'ble Bombay\nHigh Court has held that non service of notice does not\nconclusively prove the non genuineness of a\ntransacttion. By producing various documents the\nassessee had proved that balance of convenience

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties along with all the supporting documents in the physical form before the AO. 3. Non service of notice/ summon to supplier cannot be a ground for 3. 3. 3. Non service of notice/ summon to supplier cannot be a ground ... service of notice/ summon to supplier cannot be a ground for Non service of notice/ summon to supplier cannot be a ground for making the addition making the addition making the addition making the addition With regard to remarks made by the AO that summons issued to various purchase parties

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT, CENTRAL CIRCLE-05, DELHI

ITA 5520/DEL/2025[2023-24]Status: DisposedITAT Delhi20 Mar 2026AY 2023-24
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties\nalong with all the supporting documents in the physical form\nbefore the AO.\n3. Non service of notice/ summon to supplier cannot be a ground for\nmaking the addition\nWith regard to remarks made by the AO that summons issued to\nvarious ... purchases made by it were bogus.\nIn the case of Nikunj Exim Export, the Hon'ble Bombay\nHigh Court has held that non service of notice does not\nconclusively prove the non genuineness of a\ntransacttion. By producing various documents the\nassessee had proved that balance of convenience

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE-05, DELHI

ITA 5519/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23
Section 132Section 133(6)Section 143(3)Section 147Section 37Section 37(1)Section 69A

also submitted the details of all the parties\nalong with all the supporting documents in the physical form\nbefore the AO.\n3. Non service of notice/ summon to supplier cannot be a ground for\nmaking the addition\nWith regard to remarks made by the AO that summons issued to\nvarious ... purchases made by it were bogus.\nIn the case of Nikunj Exim Export, the Hon'ble Bombay\nHigh Court has held that non service of notice does not\nconclusively prove the non genuineness of a\ntransacttion. By producing various documents the\nassessee had proved that balance of convenience

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