“order under section 148A(d)”

ReassessmentSection 148ASection 148A771 judgments

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

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

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

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

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

DINDAYAL AGARWAL,BERHAMPUR vs. THE INCOME TAX OFFICER, WARD-1, BERHAMPUR., 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

April 2022 issued under Section 148 of the Act. One of the grounds raised is that the sanction to pass the order under Section 148A(d) of the Act and issuance of notice under Section 148 of the Act is invalid inasmuch as the sanction has been admittedly issued ... Respondents are directed to make available to Petitioner copy of the approval form as well as the approval accorded for issuance of order under Section 148A(d) and Section 148 of the Act within one week from this order being uploaded.” 7. Similarly, in the case of Haresh Kumar Dungarmal

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

transactions reflected in his bank account. However, the assessee did not respond to the 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

DANDEBOINA RAMESH,WARANGAL vs. ITO, WARD-(1), WARANGAL

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

ITA 1661/HYD/2025[2015-16]Status: DisposedITAT Hyderabad13 Mar 2026AY 2015-16

Section 115Section 139Section 144BSection 147Section 148Section 148ASection 149Section 69A

source of the said cash deposits. However, the assessee did not comply with the said notice. Consequently, the Ld. AO passed an order under section 148A(d) of the Act on 07.04.2022 and issued notice under section 148 of the Act dated 07.04.2022. In response to the notice issued under

GOPI KISHAN MAKHARIA,BHIWANI vs. ITO-1, BHIWANI

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

ITA 8727/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2017-18 Gopi Kishan Makharia, Vs Ito-1, Shree Saraswati Spinning Mills, Bhiwani, Birla Colony, Tosham Road, Haryana. Bhiwani, Haryana. Pan: Abhpm8102F (Appellant) (Respondent) Assessee By : Shri S.S. Nagar, Ca Revenue By : Shri Ravi Kant Chaudhary, Sr. Dr Date Of Hearing : 12.03.2026 Date Of Pronouncement : 13.03.2026 Order Per Madhumita Roy, Jm:

For Appellant: Shri S.S. Nagar, CAFor Respondent: Shri Ravi Kant Chaudhary, Sr. DR

Section 147Section 148Section 148ASection 151Section 250

paper book filed before us. Notice under Section 148A(b) of the Act was issued on 25.05.2022 and the order under Section 148A(d) was passed on 29.07.2022. These two notices were issued pursuant to the new regime and further in view of the order passed ... Assessing Officer was required to obtain approval under Section 151 of the Act under the new regime before passing an order under Section 148A(d) of the Act or issuing notice under Section 148 of the Act. In this regard, Ld. Counsel has drawn our attention to the relevant observation

BMR OVERSEAS LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(2), C.R. BUILDING DELHI 110002, DELHI

In the result the appeal of the assessee is allowed

ITA 6646/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Mar 2026AY 2017-18

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2017-18 Bmr Overseas Limited, Vs. Dcit, Circle 4(2), Zb-33/487, Plot No. 4 & 5, C.R. Building, Dilshad Garde New Delhi Industrial Area, Shahdara, Delhi – 110 095 [Pan No. Aafcb8509D) (Appellant) (Respondent)

Section 115BSection 143Section 147Section 148Section 151Section 156Section 157ASection 68

Page 16-17) for the A.Y. 2017-18 by obtaining the approval of the Pr. Commissioner, Delhi-01 and consequent order under section 148A(d) of the Act on 26-07-2022 (copy placed at APB Page 13-15) was issued, which is against the law and the proposition laid

SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

In the result, the appeal of the assessee is allowed

ITA 646/RJT/2025[2016-17]Status: DisposedITAT Rajkot12 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 646/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Shiv Extrusion Vs. Income Tax Officer Plot No.3978 Phase Iiiroad Income Tax Office, Ito Ward No.-R Dared, Jamnagar 2(10), Jamnagar, Income 361004, Gujarat, India, Jamnagar Tax Office, Shiv Smruti, Jamnagar, Jamnagar, Gujarat, 361008, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abkfs7199F (Appellant) (Respondent) Appellant By : Shri Ramesh M. Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23/12/2025 Date Of Pronouncement : 12/03/2026

For Appellant: Shri Ramesh M. Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. Sr. DR

Section 144BSection 147Section 148Section 149Section 149(1)(b)Section 151Section 151(1)Section 151ASection 250

considering 15 days' time to file reply by the assessee, the due date would be 07.06.2022. The petitioner filed no reply. The order under section 148A(d) of the Act as well as notice under section 148 of the Act was issued on 28.07.2022. considering However, the period of limitation

VIKAS CHANDRAKANTBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

ITA 25/AHD/2026[2019-20]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Jignesh Parikh, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 147Section 148Section 148ASection 151Section 68

Nos.1 and 2, the assessee challenged the validity of reopening of assessment and contended that the notice under section 148A(b) and order under section 148A(d) were issued without proper application of mind and that the notice under section 148 of the Act had been issued by the Jurisdictional

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 612/RJT/2025[2016-17]Status: DisposedITAT Rajkot10 Mar 2026AY 2016-17

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

counted five times making it wrong reporting by bank - However, Assessing Officer did not consider such reply filed by assessee and passed order under section 148A(d) along with notice under section 148 - It was clear that from reasons recorded in notices issued under section 148A(a) and section 148A ... counted five times making it wrong reporting by bank - However, Assessing Officer did not consider such reply filed by assessee and passed order under section 148A(d) along with notice under section 148 - It was clear that from reasons recorded in notices issued under section 148A(a) and section 148A

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

ITA 611/RJT/2025[2017-18]Status: DisposedITAT Rajkot10 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 10Section 10(23)(iiia)Section 11Section 139Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 149(1)(b)

DCIT CIRCLE-4(1)(1), AHMEDABAD, VEJALPUR vs. SHREE NAKODA TEXFAB PRIVATE LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 2232/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad09 Mar 2026AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 148ASection 68

under section 148 under TOLA by the Revenue and thereafter date of supplying information to the assessee and date of passing of order under section 148A(d) and date of issuance of notice under section 148 of the Act so as to consider whether issuance notice under section ... days' time to file reply by the assessee, the due date would be 15.06.2022. The petitioner filed reply on 20.06.2022. The order under section 148A(d) of the Act as well as notice under section 148 of the Act was issued on 30.08.2022. However, considering the period of limitation from

KALPANA SANJAY PAWAR,MUMBAI vs. ITO WD-41(1)(2), MUMBAI

ITA 9047/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Mar 2026AY 2017-18

Bench: the Tribunal challenging the validity of the re-assessment proceedings raising, inter alia, the following grounds: "2. On the facts and circumstances of the case and in law, the learned Assessing Officer has erred in issuing the order under Section 148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-1, Mumbai which was not the correct 'specified authority' as per Section 151 who should have approved it when three years have already elapsed from the

For Appellant: Shri Aditya RamachandranFor Respondent: Ms. Deepika Arora

Section 1Section 144BSection 147Section 148Section 148ASection 151Section 151A

Section 148A(b) of the Act (‘New Regime’ introduced by the Finance Act, 2021 w.e.f. 01/04/2021). Thereafter, The Assessing Officer passed Order under Section 148A(d) of the Act and issued notice under Section 148 of the Act (New Regime) in July, 2022 after obtaining approval/sanction from the Principal Commissioner ... grounds: “2. On the facts and circumstances of the case and in law, the learned Assessing Officer has erred in issuing the order under Section 148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-1, Mumbai which was not the correct 'specified

SUDHIR DAMJI BHARANI,MUMBAI vs. ITO WD-27(3)(1), NAVI MUMBAI

ITA 9046/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Mar 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Aditya RamachandranFor Respondent: Ms. Deepika Arora

Section 144BSection 147Section 148Section 148ASection 149Section 151

Section 148A(b) of the Act (‘New Regime’ introduced by the Finance Act, 2021 w.e.f. 01/04/2021). Thereafter, The Assessing Officer passed Order under Section 148A(d) of the Act and issued notice under Section 148 of the Act (New Regime) in July, 2022 after obtaining approval/sanction from the Principal Commissioner ... circumstances of the case and in law, the 2 Assessment Year 2017-2018 learned Assessing Officer has erred in issuing the order under Section 148A(d) and the notice under Section 148 after obtaining the approval of the approval of PCIT-27, Mumbai which was not the correct 'specified authority

ITO 19 1 5 MUMBAI, MUMBAI vs. JOHRATUSSHARAF SYEDNA MUFADDAL SAIFUDDIN, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 9040/MUM/2025[AMRPS6217J]Status: DisposedITAT Mumbai09 Mar 2026

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2017-18 Ito – 19(1)(5) Vs. Johratussharf Syedna 502, Piramal Chembers Mufaddal Saifuddin Lalbaug, Mumbai – Saifee Mahal, Ag Bell 400012. Marg, Mumbai – 400006. Pan/Gir No. Amrps6217J (Applicant) (Respondent)

Section 147Section 148Section 148ASection 151Section 250

year under consideration. Subsequently, the Assessing Officer initiated reassessment proceedings and issued notice under section 148 dated 30.07.2022 after passing an order under section 148A(d). The reassessment was completed by passing an order under section 147 r.w.s. 144B making certain additions. 3. Aggrieved thereby, the assessee filed appeal before ... relevant Assessment Year (in the present case A.Y. 2017-18) expired on 30.06.2021, whereas Respondent No.1, despite passing order under section 148A(d) on 18.08.2022, and issuing notice under section 148 on 23.08.2022 [in respect of Assessment Year 2017-18], has obtained approval of Respondent No.2

INCOME TAX OFFICER - 41(4)(4), MUMBAI, MUMBAI vs. SHAREEKA PRASANNA SHETTY, MUMBAI

ITA 9039/MUM/2025[2017]Status: DisposedITAT Mumbai09 Mar 2026

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarincome Tax Officer- Shareeka Prasanna 41(4)(4) Shetty, Room No. 854D, Vs. A8, Nanddham Chs, Kautilya Bhavan, G Bangur Nagar, Block, Bkc, Mumbai – Goregaon West, 400 051. Mumbai-400 090 Pan/Gir No. Borps9704P (Applicant) (Respondent) Revenue By Shri Ankit Tiwari, Ld. Dr Assessee By Ms. Shareeka Shetty (Assessee Herself) Date Of Hearing 05.03.2026 Date Of Pronouncement 09.03.2026

Section 144BSection 147Section 148Section 148A

entered into transactions relating to purchase of immovable properties. Based on the said information, proceedings under the reassessment provisions were initiated. An order under section 148A(d) was passed and notice under section 148 dated 15.03.2024 was issued. In response, the assessee filed a return of income declaring total income

SHREE SAI HOSPITALITY,MUMBAI vs. INCOME TAX OFFICER, WARD 2(1), MUMBAI, THANE

In the result, the appeal of the assessee is allowed

ITA 9019/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Mar 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2018-19 Shree Sai Hospitality Vs. Ito, Ward 2(1) C/32, Harias Dream Ashar It Park, 6Th Floor Park, Mira Bhayander Road No. 16Z, Wagle Road, Mira Road (E), Industraial Estate, Thane – Mira-Bhayandar – 400604. 401107. Pan/Gir No. Acyfs5492G (Applicant) (Respondent)

Section 144Section 144BSection 147Section 148Section 151Section 250Section 69

Section 151 of the Act prescribes the authority whose prior approval is required before issuing notice under section 148 or passing an order under section 148A(d). The relevant provision reads as under: “151. Sanction for issue of notice. Specified authority for the purposes of section 148 and section 148A

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