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“order under section 148A(d)”

ReassessmentSection 148ASection 148A771 judgments

The decision most relied on for order under section 148A(d) is Union of India v. Ashish Agarwal (444 ITR 1), cited in 524 judgments on BharatTax.

Leading authorities on order under section 148A(d)

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.

Pvt. Ltd. v. DCIT
466 ITR 474 · 2024 · High Court
53
citing judgments

Reassessment notices under Section 148A, issued in the context of faceless assessment proceedings, must be issued by the designated Faceless Assessing Officer and not by a Jurisdictional Assessing Officer.

Samp Furniture (P) Ltd. v. ITO
165 Taxmann.com 581 · 2024 · High Court
50
citing judgments

The issuance of a notice under section 148A, including the order under section 148A(d), is a mandatory procedural step before reassessment proceedings can be initiated under section 147/148. Failure to comply with this requirement renders the subsequent reassessment proceedings invalid.

Infrastructure Pvt. Ltd. v. ITO
463 ITR 702 · 2024 · High Court
32
citing judgments

The validity of sanction for issuing orders under section 148A(d) and notices under section 148 must be tested with reference to the amended section 151. If sanction is not granted by an authority specified under section 151(ii), such orders and notices are invalid and liable to be quashed.

Sundaram Multi Pap Ltd. v. ACIT
164 Taxmann.com 414 · 2024 · High Court
31
citing judgments

An order passed under Section 148A(d) and subsequent proceedings are void if the Assessing Officer provides insufficient opportunity for the assessee to file a reply before issuing the notice under Section 148A(b).

Holiday Developers (P.) Ltd. v. ITO
159 Taxmann.com 178 · 2024 · High Court
28
citing judgments

Where more than three years have expired from the end of a relevant assessment year, the sanctioning authority under section 151(ii) for reassessment proceedings must be the Principal Chief Commissioner, not the Principal Commissioner. An order under section 148A(d) and notice under section 148 based on the latter's approval are liable to be quashed.

Core Logistic Company v. Assistant Commissioner of Income-tax
175 Taxmann.com 453 · 2025 · High Court
26
citing judgments

The Principal Commissioner or Commissioner is the specified authority for issuing a notice under Section 148 within three years when the amount involved exceeds fifty lakhs, as per Section 151(i) and Section 149(1). An order under Section 148A(d) requires approval from such a specified authority.

Royal Bitumen (P.) Ltd. v. ACIT
164 Taxmann.com 606 · 2024 · High Court
25
citing judgments

Orders passed under section 148A(d) and subsequent reassessment proceedings are vitiated if the Assessing Officer fails to provide a proper opportunity of hearing to the assessee before issuing the notice.

Judgments citing order under section 148A(d)

Ankitjain, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed in

ITA 913/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, CA
Section 115BSection 147Section 148Section 148ASection 292CSection 69

148A(d) of the Act. In this regard, the Ld. AR submitted that the notice under section 148 as well as the order under section 148A(d) of the Act were issued by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary ... Ankit Jain Hyderabad faceless reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 30.03.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name

Sanjeev Kumar Nalam, Hyderabad vs. ITO, Ward-1, Nirmal

In the result, the appeal of the assessee is allowed

ITA 669/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Dec 2025AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.669/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Sanjeev Kumar Nalam Vs. Income Tax Officer Hyderabad Ward – 1 Pan:Avdpn0497L Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Waseem UR Rehman, Sr.DR
Section 147Section 148Section 148ASection 149(1)Section 151Section 153

invalid, as the Assessing Officer did not follow the procedure laid down under Section 148A. The Assessing Officer did not pass an order under Section 148A(d) and did not serve any such order on the appellant before issuing the notice under Section 148. Hence, the notice itself ... fifth provisos or extended by the sixth proviso to sub- section (1) of Section 149. 49. In the present case, the order under Section 148A(d) and notice under Section 148 have been issued on 07.04.2022 relatable to the relevant Assessment Year 2018- 19 i.e., after more than three years

DCIT (Exemptions), Circle 1(1), Hyderabad vs. National Institute of Rural Development and Panchayati Raj, Hyderabad

In the result, both the appeal filed by the Revenue and cross- objection filed by the assessee are dismissed

ITA 1211/HYD/2025[2016-17]Status: DisposedITAT Hyderabad19 Dec 2025AY 2016-17

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 11Section 124(3)Section 139Section 148

Nos.1210 and 1211/Hyd/2025 & C.O. Nos.27 and 28/Hyd/2025 National Institute of Rural Development & Pranchayati Raj Therefore, the A.O. passed the order under Section 148A(d) of the Income-tax Act on 20.04.2022. Along with the said order, notice under Section 148 of the Act, dated 21.04.2022 was issued. In response

Blackstone Overseas Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the both appeals of the assessee are allowed

ITA 2027/KOL/2025[2018-2019]Status: DisposedITAT Kolkata18 Dec 2025AY 2018-2019

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

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pradeep Dung Dung, DR
Section 143(1)Section 143(2)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.” 2.5. Similarly, in the case of Haresh kumar Dungarmal

M/S. Blackstone Overseas Pvt. Ltd., Kolkata vs. I.T.O., Ward-5(1), Kolkata

In the result, the both appeals of the assessee are allowed

ITA 2026/KOL/2025[2016-2017]Status: DisposedITAT Kolkata18 Dec 2025AY 2016-2017

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

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pradeep Dung Dung, DR
Section 143(1)Section 143(2)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.” 2.5. Similarly, in the case of Haresh kumar Dungarmal

Badma Baribooranam, Tuticorin vs. ITO, Ward-1, Tuticorin

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

ITA 3498/CHNY/2025[2015-16]Status: DisposedITAT Chennai18 Dec 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.3498/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Badma Baribooranam, Vs. The Income Tax Officer, No. 26, Vannar 1St Street, Ward 1, Tuticorin 628 003. Tuticorin. [Pan: Bcypp9880L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri P.M. Kathir, Advocate ""थ" की ओर से/Respondent By : Ms. Latchana, Jcit सुनवाई की तारीख/ Date Of Hearing : 16.12.2025 घोषणा की तारीख /Date Of Pronouncement : 18.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 08.10.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2015-16. 2. In Ground No. 2.3, The Assessee Challenged That The Reopening Itself Is Bad In Law As The Same Was Jurisdictionally Invalid, The Ld. Cit(A) Erred In Failing To Annul The Reopening & The Subsequent Order Of Reassessment.

For Appellant: Shri P.M. Kathir, AdvocateFor Respondent: Ms. Latchana, JCIT
Section 147Section 148Section 148A

pages 5 & 7, 11 & 13 & 14 of the paper book and submits that the notice under section 148A(b) of the Act, order under section 148A(d) of the Act and notice under section 148 of the Act dated 19.04.2022 respectively were issued by the jurisdictional Assessing Officer. Further ... Further, we note that the notice under section 148 of the Act was issued by the Jurisdictional Assessing Officer and also passed order under section 148A(d) of the Act. On perusal of the decision of the Hon’ble High Court of Madras in the case of TVS Credit Services

Jaya Juneja, Indore vs. Income Tax Officer Ward 1(4), Indore

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

ITA 813/IND/2024[2015-16]Status: DisposedITAT Indore17 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Anil Kamal Garg, CA & Shri Aayush Garg, CAFor Respondent: Shri Ashish Porwal, Sr. DR
Section 147Section 148A

hold that sufficiency of material cannot be examined at this stage. Ground No. 4 alleging that the order under section 148A(d) was non-speaking was also rejected by CIT(Appeals) on the ground that the Assessing Officer had passed a reasoned order discussing the issue in detail. Grounds

Kilaru Venkata Satish, Krishna Dist vs. DCIT, Central Circle-1(3), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 933/HYD/2025[2018-19]Status: DisposedITAT Hyderabad17 Dec 2025AY 2018-19

Bench: Us), Which Reads As Under:

Section 147Section 148Section 148ASection 151Section 68

commensurate with the income returned by him for the year under consideration, initiated proceedings under section 147 of the Act. Order under section 148A(d) of the Act, dated 11/04/2022 was passed by the Jurisdictional Assessing Officer (“JAO”). 5. Thereafter, the AO in absence of any material placed on record ... fifth provisos or extended by the sixth proviso to sub-section (1) of Section 149. 49. In the present case, the order under Section 148A(d) and notice under Section 148 have been issued on 07.04.2022 relatable to the relevant Assessment Year 2018- 19 i.e., after more than three years

Krishnaveni Kokkula, Hyderabad vs. ITO., Ward-9(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 558/HYD/2025[2016-17]Status: DisposedITAT Hyderabad17 Dec 2025AY 2016-17

Bench: Us:

Section 147Section 69A

filed her return of income, initiated proceedings under Section 147 of the Act. Order under Section 148A(d) of the Act, dated 25.03.2023, was passed by the Jurisdictional Assessing Officer (JAO). Notice under section 148 of the Act, dated 25/03/2023, was issued to the assessee ... notices under section 148 of the Act were issued by the local jurisdictional officer and not in the prescribed faceless manner. The order under section 148A(d) of the Act and the notices under section 148 of the Act are issued on 29-4-2022, i.e., after the "Faceless Jurisdiction

Laxmi Venkata Krishna Rice Corporation, Nalgonda vs. ITO, Ward-1, Suryapet

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 1700/HYD/2025[2017-18]Status: DisposedITAT Hyderabad17 Dec 2025AY 2017-18

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 148ASection 234ASection 69A

bank account No.032913100023220, Kodad Branch, Suryapet, but had not filed its return of income, initiated proceedings under section 147 of the Act. Order under section 148A(d) of the Act, dated 27/07/2022 was passed by the AO. Thereafter, the AO issued notice under section 148 of the Act, dated 29/07/2022 ... fifth provisos or extended by the sixth proviso to sub-section (1) of Section 149. 49. In the present case, the order under Section 148A(d) and notice under Section 148 have been issued on 07.04.2022 relatable to the relevant Assessment Year 2018- 19 i.e., after more than three years

C-2016 Itchiputhur Paccs, Vellore vs. ITO, Ward-1, Vellore

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

ITA 2191/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Dec 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.2191/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 C-2016 Itchiputhur Primary Agricultural Vs. The Income Tax Officer, Coop. Credit Society, 12Th Road, Ward 1, Itchiputhur Village, Arakkonam Tk, Vellore. Vellore 631 003. [Pan: Aabac1870C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri J. Saravanan, Advocate ""थ" की ओर से/Respondent By : Ms. Babitha, Jcit सुनवाई की तारीख/ Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2019-20. 2. We Find That This Appeal Is Filed With A Delay Of 5 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, In 2

For Appellant: Shri J. Saravanan, AdvocateFor Respondent: Ms. Babitha, JCIT
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 80P(2)(a)

page 5, 8 & 10 of the paper book and submits that the notice under section 148A(b) of the Act dated 24.01.2023, order under section 148A(d) of the Act dated 29.03.2023 and notice under section 148 of the Act respectively are issued by the jurisdictional Assessing Officer. He also ... Further, we note that the notice under section 148 of the Act was issued by the Jurisdictional Assessing Officer and also passed order under section 148A(d) of the Act. On perusal of the decision of the Hon’ble High Court of Madras in the case of TVS Credit Services

Asia Coke Pvt. Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

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

ITA 1403/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Dec 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.1403/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Asia Coke Private Limited, Vs. The Deputy Commissioner Of Bascon Futura Sv, 4Th Floor, Income Tax, Venkatanarayana Road, T. Nagar, Corporate Circle 1(1), Chennai 600 017. Chennai. [Pan: Aakca4655Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. S. Sanchita, Advocate ""थ" की ओर से/Respondent By : Ms. E Pavuna Sundari, Cit सुनवाई की तारीख/ Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.01.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. We Find That This Appeal Is Filed With A Delay Of 45 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, In 2

For Appellant: Ms. S. Sanchita, AdvocateFor Respondent: Ms. E Pavuna Sundari, CIT
Section 142(1)Section 147Section 148Section 148ASection 68Section 69C

since the assessee made foreign remittance of ₹.11,05,70,230/- and no return of income filed, the Assessing Officer passed the order under section 148A(d) of the Act dated 26.03.2022. The Assessing Officer issued notice under section 142(1) of the Act dated 06.10.2022 and in response ... page 1, 2 & 5 of the paper book and submits that the notice under section 148A(b) of the Act dated 14.03.2022, order under section 148A(d) of the Act dated 26.03.2022 and notice under section 148 of the Act respectively were issued by the jurisdictional Assessing Officer. She also

Shivi Mukesh Kumar, Mumbai vs. ACIT, Circle 22(1), Mumbai

In the result, the appeal is partly allowed as indicated above

ITA 5293/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Jagadishshivi Mukesh Kumar Acit, Circle 22(1) D-1402, Hubtown Seasons, Mumbai Next To Fine Arts Society, Vs. Ramakrishna Chemburkar Marg, Chembur, Mumbai-400 071 Pan/Gir No. Aqapk 9881 H (Appellant) : (Respondent) Appellant By : Shri Dharan V. Gandhi – Advocate & Ms. Vinita A. Nara – Advocate Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 11.12.2025 Date Of Pronouncement : 17.12.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against The Order Dated 01.07.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y.) 2016-17. 2. Though, The Assessee Has Raised Multiple Grounds, However, At The Time Of Hearing, Ld. Counsel Appearing For The Assessee Specifically Drew Our Attention To Ground No. 6, Which Reads As Under: 6. The Sanction U/S. 151 Is Bad In Law & As A Result, The Reassessment Proceeding Is Bad In Law. 3. Referring To This Ground, Ld. Counsel Submitted, At The Very Outset, This Issue May Be Considered And, If Warranted The Other Issues Can Be Taken Up Thereafter. As Could Be Seen

For Appellant: Shri Dharan V. Gandhi – Advocate &For Respondent: Shri Arun Kanti Datta – CIT DR
Section 133ASection 143(3)Section 147Section 148Section 151Section 35(1)(ii)

relating to the very same assessment year has held as under: 5. The Petitioner has contended that in the present case, the order under section 148A(d) dated 13.07.2022 was passed beyond three years from the end of the relevant Assessment Year 2016-17. Consequently, according to the provisions ... officer was required to obtain prior approval of the specified authority according to Section 151 of the new regime before passing an order under section 148A(d) or issuing a notice under section 148. These notices ought to have been issued following the time limits specified under section

Sat Narain Sharma, Rohtak vs. Ward 2, Rohtak

In the result, appeal of the assessee is allowed

ITA 6167/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Pawan Singh(Physical Hearing) Sat Narayan Sharma Ward-2, Rohtak Village & Post Office Bohar, Dist. Vs Aayakarbhawan, Rohtak, Rohtak, Haryana – 124021. Haryana – 124001. [Pan: Afjps5702B] Appellant / Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 234ASection 254(1)

notice under section 148 is placed at page no. 8 of paper book. The case of assessee was reopened after passing order under section 148A(d) dated 07.04.2022. The assessee was supplied the basis of issuance of show cause notice under section 148A(b), wherein, the assessing officer annexed ... reply of assessee concluded that it a fit case for issuing notice under section 148, despite recording all such facts in order under section 148A(d) dated 07.04.2022. The assessing officer ultimately in the assessment order has made addition of Rs. 26,75,000/-. The lower authorities have not considered

Dy. Commissioner of Income Tax, Central Circle 3, Delhi vs. Pankaj Goel, Delhi

ITA 4159/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Dy. Commissioner Of Vs. Sh. Pankaj Goel, Income Tax, 662/3A, Ghati Road, Central Circle-3, Anand Paravt, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) With C.O. No.236/Del/2025 [Arising Out Of Ita No.4159/Del/2025] Assessment Year: 2017-18 Sh. Pankaj Goel, Vs. Dy. Commissioner Of Income 662/3A, Ghati Road, Tax, Anand Paravt, Central Circle-3, Central Delhi, Delhi New Delhi Pan: Aswpg8949E (Appellant) (Respondent) Assessee By Ms. Mansi Jain, Adv. Sh. Siddharth Bajaj, Adv. Department By Sh. Siddharth Bhim Singh Meena, Cit(Dr) Date Of Hearing 08.12.2025 Date Of Pronouncement 17.12.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.4159/Del/2025 Along With Assessee’S Cross Objection C.O. No. 236/Del/2025 For Assessment & C.O. No.236/Del/2025

Section 13ASection 147Section 148Section 148ASection 151Section 29A

days, the AO had, by virtue of the fourth proviso to Section 149(1) of the Act, seven days to pass an order under Section 148A(d) of the Act (which was necessarily required to accompany a notice under Section 148 of the Act). The said period expired ... Delhi); 2024 SCC OnLine Del 330.] . Consequently, the validity of sanction for issuing the orders under section 148A(d) and the notices under section 148 should be tested with reference to amended section 151. If so tested, it is evident that sanction was not granted by an authority specified under

Ankita Badal Mittal, Mumbai vs. Ward 3(3)(1), Mumbai

In the result, the appeal filed by the assessee stands partly allowed

ITA 5484/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Dec 2025AY 2017-18

Bench: Shri Sandeep Gosain

Section 147Section 148Section 149Section 151Section 250Section 68Section 69A

pages 7 to 61 of the PB). Two days as referred to above, would be available to the AO for passing the order under section 148A(d) and issuing the notice under section 148 of the Act. However, in view of the fifth and the sixth proviso below section ... period of 7 days which would make the limitation to expire on 14.06.2022 e. On 30.07.2022, the AO passed an order under section 148A(d) of the Act rejecting the objections raised by the Appellant (see pages 62 to 71 of the PB). Consequent thereto, notice dated 30.07.2022 has been

Chandini Duvvuri, Hyderabad vs. ITO (Int Taxn)-1, Hyderabad

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

ITA 1432/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Dec 2025AY 2015-16

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 147Section 148Section 148ASection 151A

Ward 9(1), Hyderabad, issued a notice under Section 148A(b) of the Act, dated 01.04.2022, which was followed by an order under Section 148A(d) of the Act, dated 04.04.2022 by 10 Chandini Duvvuri the very same A.O. and further issuance of notice under Section

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1396/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

Private Limited (contractor) of Rs.50,000/-, but not filed his return of income, initiated proceedings under section 148A(a) of the Act. Order under section 148A(d) of the Act was passed on 28/04/2022. Thereafter, the AO issued notice under section 148 of the Act, dated 28/04/2022. 4. Thereafter

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1395/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

Private Limited (contractor) of Rs.50,000/-, but not filed his return of income, initiated proceedings under section 148A(a) of the Act. Order under section 148A(d) of the Act was passed on 28/04/2022. Thereafter, the AO issued notice under section 148 of the Act, dated 28/04/2022. 4. Thereafter

Selvaraj Arokia Sagaya Raj, Chennai vs. DCIT, Ncc-22(1), Chennai

In the result, the appeal of the assessee is allowed, and the stay application is dismissed as infructuous

ITA 3597/CHNY/2025[2018-19]Status: DisposedITAT Chennai12 Dec 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3597/Chny/2025 & S.A No.118/Chny/2025 िनधा%रण वष% /Assessment Year: 2018-19 Selvaraj Arokia Sagaya Raj, The Dy. Commissioner Of Income 6/9 Ff1, Soundariya Apartments, Vs. Tax, Voc 2Nd Main Road, Non Corporate Circle-22(1), Kodambakkam, Tambaram, Chennai. Chennai – 600 024. Pan: Aeypa 8464Q

For Appellant: Mr. N.V.Krishnan, AdvocateFor Respondent: Ms. Babitha, JCIT
Section 147Section 148Section 148ASection 250

marked as Annexure - A1. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under section 148A(d) of the Act, dated 27/04/2022, bearing DIN No. ITBA/AST/F/148A/2022-23/1042880971(1) passed by the Respondent No.1 for the assessment year 2018-19 herein marked