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“section 148A”

ReassessmentSection 148ASection 148A2,377 judgments

The decision most relied on for section 148A is Union of India v. Rajeev Bansal (469 ITR 46), cited in 713 judgments on BharatTax.

Leading authorities on section 148A

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.

CIT v. Walfort Share & Stock Brokers (P.) Ltd.
326 ITR 1 · 2010 · Supreme Court
543
citing judgments

For attracting Section 14A disallowance, there must be a proximate cause relating the expenditure to actual tax-exempt income, and such disallowance is not automatic but requires positive material. Additionally, Section 94(7) on dividend stripping only ignores losses to the extent of dividend received for assessment years post-April 1, 2002, allowing the remaining loss.

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

Kunhayammed v. State of Kerala
245 ITR 360 · 2000 · Supreme Court
361
citing judgments

An order refusing special leave to appeal to the Supreme Court, whether speaking or non-speaking, does not attract the doctrine of merger, meaning the order under challenge is not substituted.

Kankanala Ravindra Reddy v. ITO
156 Taxmann.com 178 · 2023 · High Court
213
citing judgments

A notice issued under section 148 of the Income Tax Act is invalid if the Income Tax Department fails to follow the prescribed procedures, including obtaining the necessary approvals under section 151 or adhering to the faceless assessment scheme mandates under section 151A.

Varghese v. ITO, Ernakulum
4 SCC 173 · 1981 · Reported
164
citing judgments

Circulars issued by the Central Board of Direct Taxes (CBDT) under Section 119 of the Income Tax Act are legally binding on the revenue authorities in their administration and implementation. This binding character applies even if the circulars depart from the correct interpretation of the law and cannot be ignored to the prejudice of the assessee.

(P.) Ltd. v. ITO
221 ITR 538 · 1996 · Supreme Court
125
citing judgments

The sanction of a specified authority under Section 151 is a mandatory procedural check before issuing a notice under Section 148. This procedural safeguard aims to prevent mechanical reopening of assessments and harassment of the assessee.

Shanmugavel Nadar v. State of Tamil Nadu
263 ITR 658 · 2003 · Supreme Court
122
citing judgments

The doctrine of merger applies when appellate jurisdiction is invoked, causing the operative part of a lower court's order or decree to merge into the superior court's order, whether it reverses, modifies, or affirms the original decision. The application of this doctrine depends on the nature of the appellate or revisional order, the scope of statutory provisions, and the subject matter challenged.

Judgments citing section 148A

Rakesh Palepu, Devarakonda vs. Income Tax Officer, Ward-1, Nalgonda

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

ITA 448/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Aug 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri B. Sri Harsha, C.AFor Respondent: Ms. P. Sumitha, SR-DR
Section 139Section 144Section 147Section 148Section 148ASection 151

strongly opposed the contention of the assessee. He submitted that the Ld. AO had issued a notice under clause (b) of Section 148A on 26.03.2022 and had granted 23 days’ time to the assessee for furnishing a reply. Referring to the first proviso to Section 151 r.w. 5th proviso ... section 149(1), the Ld. DR submitted that such time period granted to the assessee for reply under Section 148A(b) of the Act is to be excluded while computing the limitation for taking approval of prescribed authority under Section 151 of the Act. Accordingly, the outer time limit

Jayantibhai Chimanbhai Patel, Surat vs. ITO, Ward 2(3)(2), Surat

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

ITA 167/SRT/2025[2016-17]Status: DisposedITAT Surat17 Aug 2026AY 2016-17

Bench: Shri Diesh Mohan Sinha & Shri Bijayananda Pruseth

For Appellant: Shri Rajesh Upadhyay, ARFor Respondent: Shri Ajay Uke, Ld. Sr. DR
Section 147Section 148Section 148ASection 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DIESH MOHAN SINHA, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

DCIT, New Delhi vs. Vishwanath Singhal, Delhi

In the result, the appeal of the revenue is dismissed

ITA 2028/DEL/2025[2018-19]Status: DisposedITAT Delhi31 Jul 2026AY 2018-19

Bench: Shri M. Balaganeshacit, Vs. Vishwanath Singhal, Circle-58(1), 40, Priya Enclave, Delhi Delhi Pan: Aasps988Ik Assessee By : Shri Neeraj Mangla, Ca Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 27/08/2025

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 10(38)Section 115BSection 133(6)Section 147Section 148Section 68

case, addition of Rs.28,91,775/- u/s 68 is hereby deleted.” 5. Further, we find that the Learned AO while passing an order under section 148A(d) of the Act dated 26-3-2022 in para 3 had categorically given a finding that shares of Eicher Motors Limited does ... penny stock (i.e. shares of Eicher Motors Limited) which fact is also admitted by the Learned AO himself in the order passed under section 148A(d) of the Act, the said revenue appeal deserve to be dismissed as not maintainable on the ground of low tax effect as it falls

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

Assessing Officer. 17. It was argued that the reassessment framework contemplates a two-stage process, namely, the initial inquiry and formation of opinion under section 148A by the Jurisdictional Assessing Officer and the actual assessment by the faceless unit. Section 144B does not provide an exclusive machinery for pre- issuance ... rather than jurisdictional extinction. 23. In reassessment proceedings under the post-2021 regime, the statutory structure itself reflects segmentation of stages. The inquiry under section 148A, issuance of notice under section 148 and other foundational steps are ordinarily undertaken by the Jurisdictional Assessing Officer. Upon filing of return in response

Asstt. Commissioner of Income Tax, Central Circle-4, Jaipur vs. Gopal Prasad Gupta, Jaipur

The appeals of the revenue are dismissed

ITA 1765/JPR/2025[2013-14]Status: DisposedITAT Jaipur23 Mar 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

accordingly, an opportunity of being heard as per the P a g e | 4 ITA No.1764 & 1765/JPR/2025 Gopal Prasad Gupta provision of section 148A(b) of the Income Tax Act, 1961 was provided to the assessee wherein the assessee was given a show-cause on 01.06.2022 as to why said

Asstt. Commissioner of Income Tax, Central Circle-4, Jaipur vs. Gopal Prasad Gupta, Jaipur

The appeals of the revenue are dismissed

ITA 1764/JPR/2025[2016-17]Status: DisposedITAT Jaipur23 Mar 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Ratnesh Nandan Sahay

For Appellant: Sh. Rajnikant Bhatra, CAFor Respondent: Sh. Rajesh Ojha, CIT
Section 147Section 148Section 153CSection 250

accordingly, an opportunity of being heard as per the P a g e | 4 ITA No.1764 & 1765/JPR/2025 Gopal Prasad Gupta provision of section 148A(b) of the Income Tax Act, 1961 was provided to the assessee wherein the assessee was given a show-cause on 01.06.2022 as to why said

Prajyoth Kumar Adi, Hyderabad vs. ITO, Ward-4(1), Hyderabad

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

ITA 2078/HYD/2025[2020-21]Status: DisposedITAT Hyderabad20 Mar 2026AY 2020-21
Section 142(1)Section 144Section 147Section 148Section 148ASection 270A

Rs.1,44,752/-, but had not filed his return of income, initiated proceedings under section 147 of the Act. Show cause notice (SCN) under section 148A(b) of the Act, dated 19/02/2024 was issued to the assessee, which, however, was not replied by him. Thereafter, the AO passed an order ... under section 148A(d) of the Act, dated 11/03/2024. Notice under section 148 of the Act, dated 12/03/2024 was issued to the assessee. However, the assessee failed to file his return of income in compliance to the notice issued under section 148 of the Act. Also, the notices issued

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

Rs.1,44,752/-, but had not filed his return of income, initiated proceedings under section 147 of the Act. Show cause notice (SCN) under section 148A(b) of the Act, dated 19/02/2024 was issued to the assessee, which, however, was not replied by him. Thereafter, the AO passed an order ... under section 148A(d) of the Act, dated 11/03/2024. Notice under section Prajyoth Kumar Adi vs. ITO 148 of the Act, dated 12/03/2024 was issued to the assessee. However, the assessee failed to file his return of income in compliance to the notice issued under section

Javitri Devi, Delhi vs. Income Tax Officer, Ward 30(5), Delhi

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

ITA 6619/DEL/2025[2016-17]Status: DisposedITAT Delhi20 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumara.Yr. : 2016-17 Javitri Devi, Vs. Income Tax Officer, R-7, Nehru Enclave, Ward 30(5), Kalkaji New Delhi New Delhi – 110 019 (Pan: Aafpd2491M) (Appellant) (Respondent)

For Appellant: Sh. S.C. Garg, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 13Section 148Section 148ASection 151

various judgments decided the issue in favour of the assessee as under :- “18. In view of the above, the order dated 29.07.2022 passed under section 148A(d) of the Act is not sustainable. Consequently, the subsequent proceedings, including the assessment order dated 23.05.2023, cannot be sustained. Accordingly, the impugned order ... passed under section 148A(d) of the Act, the notice issued under section 13\48 of the Act as well as the assessment order dated 23.05.2023 and the demand raised pursuant thereto, are hereby set aside.” 6. Respectfully following the above decisions, we are inclined to allow the legal ground

Vineet Kumar, Dharamshala vs. Income Tax Officer, Dharmshala

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

ITA 1090/CHANDI/2025[2017-2018]Status: DisposedITAT Chandigarh19 Mar 2026AY 2017-2018

Bench: SHRI. LALIET KUMAR (Judicial Member)

For Appellant: NoneFor Respondent: Shri Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 148ASection 250(6)Section 69A

grounds, inter alia, include challenge to jurisdiction on account of alleged invalid issuance of notice under section 148, non-compliance of procedure prescribed under section 148A, improper invocation of best judgment assessment despite compliance, and failure of the authorities below to consider replies and evidences furnished by the assessee

Rajesh Kumar Mishra, Ghaziabad vs. ITO Ward 2(2)(2), Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 7401/DEL/2025[2020-21]Status: DisposedITAT Delhi18 Mar 2026AY 2020-21

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Vinod Mamgai, AdvocateFor Respondent: Shri Amit Jain, CIT (DR)
Section 147Section 148Section 148ASection 151Section 250

arbitrary, unjustified and bad in law. ii) On the facts and in the circumstances of the case and in law, no mandatory notice under section 148A of the Income Tax Act, 1961 was issued by the Ld. Assessing Officer. iii) On the facts and the circumstances of the case

Deputy Commissioner of Income Tax, Central Circle-20, Delhi, Jhandewalan vs. Krska Capital Private Limited, Delhi

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

ITA 4666/DEL/2025[2016-17]Status: DisposedITAT Delhi18 Mar 2026AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2016-17

Section 132(4)Section 143(3)Section 147Section 148Section 68

filed on the following grounds: (i) Because on facts and in law, the CIT(A) erred in not holding that the order passed under section 148A(d) and notice issued under section 148 both dt. 29-07-2022 were invalid and bad in law being time barred ... liable to be quashed. (ii) Because on facts and in law, the CIT(A) erred in not annulling the reassessment as order under section 148A(d) and notice issued under section 148 both dt. 29-07-2022 for assessment year 2016-17 were beyond the period of three years approval

Shailesh Kumar, New Delhi vs. Central Circle- 27, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3641/DEL/2025[2015-16]Status: DisposedITAT Delhi18 Mar 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Amitabh Shuklashailesh Kumar Vs Acit W-82/1, Eastern Avenue, Sainik Central Circle-27 Farms, New Delhi Jhandewalan, New Delhi Pan: Afppk1645B (Applicant) (Respondent) Appellant By Sh. R. P. Mall, Adv Respondent By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 26.02.2026 Date Of Pronouncement 18.03.2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-29, (‘Ld. Cit (A)’ For Short), New Delhi Dated 28/03/2025 For The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That, Assessee Filed Its Return Of Income For The Year Under Consideration Declaring Income Of Rs. 18,18,380/-. An Assessment Order Came To Be Passed U/S 147 Of The Act On 30/05/2023 By Computing The Income Of The Assessee At Rs. 72,84,905/- As Against The Returned Income Of Rs. 18,18,380/-. Aggrieved By The Assessment Order Dated 30/05/2023, Assessee Preferred Appeal Before The Ld. Cit(A). The Ld. Cit(A) Vide Order Dated 28/03/2025, Dismissed The Appeal Of The Assessee.

Section 147Section 148Section 148ASection 149Section 149(1)Section 149(1)(b)Section 3(1)

1 Shailesh Kumar Vs. ACIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI YOGESH KUMAR

Sasireka Boopathi, Thanjavur vs. Income Tax Officer, Thanjavur

In the result, the appeal filed by the Assessee stands Partly

ITA 4113/CHNY/2025[2019-2020]Status: DisposedITAT Chennai17 Mar 2026AY 2019-2020

Bench: Shri George George K, Vice- & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.4113/Chny/2025 "नधा"रण वष" / Assessment Year: 2019-20 Sasireka Boopathi, Vs Income Tax Officer, 1/263, Vellalar Street, Thanjavur. Saliyamangalam, Papanasam, Thanjavur – 613504 Pan: Gpfpb2689J Appellant/ Assessee Respondent / Revenue Assessee By Shri Gokularaman – Ca Revenue By Ms. V Aswathy – Jcit Date Of Hearing 18/02/2026 Date Of Pronouncement 17/03/2026 आदेश/ Order Per Inturi Rama Rao, Am : This Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Delhi Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2019-20 Dated 19.09.2025. The Assessee Raised The Following Grounds Of Appeal :

Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 148ASection 151ASection 250

Part1) dated 29th March,2022. Therefore, the Assessment Order passed by the National Faceless Assessment Unit has become null and void, since Notices under Section 148A(b), Section 148A(d) and Section 148 mentioned in the FACTS were issued by JAO and not by the National Faceless Assessment Unit

Praveen Sanjiv, Chennai vs. ITO, Ncw-7(3), Chennai

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

ITA 3834/CHNY/2025[2015-16]Status: DisposedITAT Chennai17 Mar 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3834/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Praveen Sanjiv, Vs. The Income Tax Officer, No. 45, W Block, 7Th Street, Anna Non Corporate Ward 7(3), Nagar, Chennai 600 040. Chennai. [Pan: Fzzps0216R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.02.2026 घोषणा की तारीख /Date Of Pronouncement : 17.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.12.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2015-16. 2. Ground No. 1 Raised By The Assessee Is General In Nature & Requires No Adjudication.

For Appellant: Shri D. Anand, AdvocateFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 144Section 148Section 148ASection 250(6)Section 251(1)(a)Section 56(2)(vii)Section 69

return of income was filed by the assessee. Further, the Assessing Officer issued notice under section 148 of the Act by passing order under section 148A(d) of the Act. In response to the said notice, the assessee filed various documents to explain the source for the purchase and construction

Alok Khatua, Cuttack vs. ITO, Ward-1(1), Cuttack

In the result, the appeal of the assessee is allowed

ITA 154/CTK/2026[2020-21]Status: DisposedITAT Cuttack16 Mar 2026AY 2020-21

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2020-21 Alok Khatua, Cuttack Ito, Ward-1(1), Cuttack Vs Madhupur, Belagachhia, Baranga, Cuttack-754005. (Pan: Eeypk6293H) (Appellant) (Respondent)

For Appellant: Shri S. K. Sarangi & Bishwa Jyoti Pattnaik, ARsFor Respondent: Shri Shakeer Ahamed, Sr. DR
Section 147Section 148Section 148A

submission that this order is invalid insofar as the assessee has not been given seven days time as required under the provisions of section 148A(b) of the Act. The notice u/s.148A(b) of the Act is as follows: “Notice under clause (b) of Section 148A of the Income ... u/s.148A of the Act states that the assessee shall submit the response with supporting documents on or before 18th March, 2022. Therefore, as per section 148A(b) of the Act, excluding these two das ie. Date of issuance of the notice and the date on when response is sought from

Dindayal Agarwal, Berhampur vs. The Income Tax Officer, Ward-1, Berhampur.

In the result, the appeal of the assessee is allowed

ITA 471/CTK/2025[2017-18]Status: DisposedITAT Cuttack16 Mar 2026AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarassessment Year: 2016-17 Dindayal Agarwal Ito, Ward-1, Berhampur

For Appellant: Shri Pranaya Ku. Mishra, Prashant KumarFor Respondent: Shri Shakeer Ahamed, Sr. DR
Section 148Section 148ASection 151

Deputy Commissioner of Income Tax & Ors., the sanction is invalid and consequently, the impugned order and impugned notice both dated 22nd April 2022 under Sections 148A(d) and 148 of the Act are hereby quashed and set aside.” 6. Similarly, decision of Hon'ble Bombay High Court in case ... followed the decision of Agnello Oswin Dias (supra), as under:- “1. Petitioner is impugning a notice dated 19 March 2022 issued under Section 148A(b) of the Income Tax Act, 1961 ("the Act"), the order passed under Section 148A(d) of the Act and the notice both dated 7th April

Rupinder Singh Duggal, Ahmedabad vs. The ITO, Ward-5(3)(2), Ahmedabad

In the result the appeal filed by the assessee is allowed

ITA 1921/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 147Section 148Section 148ASection 149Section 151Section 192Section 54Section 80C

raised the following Additional Grounds of Appeal: 1. The Ld. Assessing Officer has erred in law and on facts in passing the order under section 148A(d) without obtaining valid I.T.A No. 1921/Ahd/2025 A.Y. 2017-18 4 Rupinder Singh Duggal Vs. ITO sanction under section ... Officer has erred in law and on facts in not adhering the alleged sanction under section 151 of the Act while passing order under section 148A(d) of the Act, which is contrary to statutory requirements, thereby rendering the proceedings without jurisdiction and liable to be annulled. 5. We have

Nisha Rani, C/O Sahay Enterprises vs. The Income Tax Officer, Ward -1(2), Aayakar Bhawan

In the result, this appeal of the assessee is partly allowed

ITA 434/GTY/2025[2020-2021]Status: DisposedITAT Guwahati13 Mar 2026AY 2020-2021

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumarnisha Rani, I.T.O., Bedi Market, At Road, Ward-1(2), Vs. Guwahati-781001 (Assam) Guwahati. (Appellant) (Respondent) Pan No. Afjpr 7852 P Assessee By : Shri Vishesh Surana, Fca. Revenue By : Shri Santosh Kumar Karnani, Addl. Cit Date Of Hearing: 09/03/2026 Date Of Pronouncement: 13/03/2026 O R D E R

For Appellant: Shri Vishesh Surana, FCAFor Respondent: Shri Santosh Kumar Karnani, Addl
Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 69C

assessee was reopened under Section 147 of the Act by issuing notice under Section 148 of the Act on 21/03/2024 after passing order under Section 148A(d) of the Act which was preceded by issuance of show cause notice under Section 148A(b) of the Act. In compliance of which

Poreddy Sambasiva Reddy, Kadiri vs. ITO, Ward-1, Hindupur

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

ITA 1862/HYD/2025[2018-19]Status: DisposedITAT Hyderabad13 Mar 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1862/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2018-19) Poreddy Sambasiva Reddy, Vs. Income Tax Officer, Kadiri. Ward-1, Pan: Bibpr4972G Hindupur. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Nvv Gopalal Krishna, Ca Assessee Represented By राज"वका""त"न"ध"व/ : Dr. Sachin Kumar, Sr.Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 09/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 13/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Poreddy Sambasiva Reddy, Kadiri (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 22/10/2025 For The Assessment Year (“A.Y.” 2018-19. Poreddy Sambasiva Reddy Vs. Ito 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 142(1)Section 144Section 147Section 148Section 250Section 69A

Based on the information available in the Insight Portal of the Department, the Learned Assessing Officer (“Ld. AO”) issued a notice dated 22.03.2022 under section 148A(b) of the Act calling upon the assessee to explain certain transactions reflected in his bank account. However, the assessee did not respond ... said notice. Accordingly, the Ld. AO passed an order under section 148A(d) of the Act on 02.04.2022 holding that it was a fit case for issuance of notice under section 148 of the Act and consequently issued notice under section 148 of the Act on 03.04.2022. During the reassessment