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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)

Assistant Commissioner of Income Tax, Central Circle-3(1), Kolkata vs. Rajshri Iron Industries Private Limited, Kolkata

In the result, both the appeals of the Revenue are dismissed

ITA 2385/KOL/2024[2018]Status: DisposedITAT Kolkata21 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: S/Shri Praveen Kishore &
Section 147Section 148Section 148ASection 69C

income. However, the assessing authority somehow, ignored and disregarded, all such factual submissions of the assessee and proceeded with issuing an order under section 148A(d) of the Act, followed by the corresponding Reassessment Notice u/s 148 of the Act, on exactly the same lines of escapement of income ... 148A(b) but would certainly not vest it with the power to issue a re-assessment notice under Section 148 post an order under Section 148A(d). …… 16. This Court is of the opinion that significance of issuance of a show cause notice at a stage prior to issuance

DCIT, Circle- 19(1), Delhi vs. Rakshit Buildcon Pvt. Ltd., Delhi

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

ITA 4727/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmadcit, Circle 19 (1), Vs. Rakshit Buildcon Pvt. Ltd., C – 1/207, 2Nd Floor, Delhi. Sector 11, Rohini, New Delhi – 110 085. (Pan : Aaecr2414E) (Appellant) (Respondent) Assessee By : Shri Salil Aggarwal, Sr. Advocate Shri Shailesh Gupta, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Order : 21.11.2025 O R D E R Per S.Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of Ld. Commissioner Of Income Tax (Appeals), Delhi-23 [“Ld. Cit(A)”, For Short] Dated 14.08.2024 For Ay 2017-18. “(I) "Whether On Facts & Circumstances Of The Case & In Law, The Ld. Cit(A), Has Erred In Not Appreciating That Detailed Investigation Was Already Carried Out By The Investigation Wing On The Issue Of Bogus Short Term Capital Loss From Alankit Group & The Assessee Was Not Able To Substantiate Its Claim With Evidences."

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 147Section 148Section 151

Since assessee did not file any reply within due date given, i.e., 7-6-2022, Assessing Officer passed an order under section 148A(d) dated 28-7-2022 and issued a notice under section 148 dated 28-7-2022 - It was noted that original notice under section 148 was issued ... reply to notice that was between 7-6-2022 to 9-6-2022 - Held,yes - Whether thus, he was required to pass order under section 148A(d) and issue notice 8 under section 148 on or before 9-6-2022 and accordingly, impugned notice under section 148 dated

Anjaneyulu Reddy Ammireddy, Vinukonda vs. Income Tax Officer, Ward-1, Narasaraopet

ITA 542/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.542/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Vs. Anjaneyulu Reddy Ammireddy, Income Tax Officer, Vinukonda. Ward-1, Pan: Aelpa3332C Narasaraopet. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Gvn Hari, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 06/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 25/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/02/2024. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal:

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151Section 151ASection 69

Notice under section 148A(b) of the Act, dated 22/03/2022, was issued to the assessee. Thereafter, the AO passed an order under section 148A(d) of the Act, dated 08/04/2022, wherein it was held by him that it was a fit case for issuing notice under section

Ashok Rudraraju, Visakhapatnam vs. Income-Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 439/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 151(1)Section 151ASection 251(1)(a)Section 69A

source of the same was offered by the assessee, initiated proceedings under section 147 of the Act. The AO passed an order under section 148A(d) of the Act, dated 27/07/2022. Thereafter, the AO issued notice under section 148 of the Act, dated 27/07/2022. In compliance, the assessee filed ... 144B of the Act, dated 15.05.2023 had been framed by the Faceless Assessment Unit of the Income-tax Department, based on the order under Section 148A(d) of the Act, dated 27.07.2022 and notice under Section 148 of the Act, dated 27.07.2022 passed/issued by the Jurisdictional Assessing Officer

Sonu Agarwal, Jaipur vs. Income Tax Officer Ward 1(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 1263/JPR/2025[2016-2017]Status: DisposedITAT Jaipur19 Nov 2025AY 2016-2017

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Siddharth Ranka, Adv. &For Respondent: Shri Gaurav Awasthi, JCIT
Section 10(38)Section 139Section 147Section 148Section 148ASection 250

compliance to the said show-cause, the reply furnished by the assessee on 11.06.2022 has been reproduced in the order under section 148A(d) dated 26.07.2022, are as under : “ I had purchased shares of M/s. Appu Marketing and Manufacturing Limited/Ejecta Marketing Limited (Listed in Bombay Stock Exchange), Script code ... considered the reply furnished by the assessee as well as objection raised but could not found it tenable. Accordingly, the AO passed order under section 148A(d) concluding that on the basis of material available on record, the case of the assessee is a fit case for issuance of notice

Subhadra Kumari Mudigonda, Hyderabad vs. ITO., Ward-1(3), Tirupati

In the result, the appeal of the assessee is allowed in terms of our above observation

ITA 985/HYD/2025[2015-16]Status: DisposedITAT Hyderabad19 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.985/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Smt. Subhadra Kumari Vs. Income Tax Officer Mudigonda, Hyderabad Ward 1(3) Pan: Airpm9926C Tirupati (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Abhinav Pitta, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Subhadra Kumari Mudigonda (“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 25.04.2025 For The A.Y 2015-16. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri Abhinav Pitta, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151A(1)

this regards the Ld. AR submitted that the notice under section 148 of the Act and 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 to the scheme ... faceless reassessment introduced by the CBDT. 5. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 07.04.2022 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name and designation

Kineta Global Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

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

ITA 800/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.800/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Kineta Global Limited, Vs. Deputy Commissioner Hyderabad. Of Income Tax, Circle-2(1), Pan: Aacck7944A Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Venkateswarlu, Tax Consultant रधजस् व द्वधरध/Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 12/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”) Dated 21/02/2024 For The Assessment Year 2018-19. The Assessee Company

For Appellant: Sri S. VenkateswarluFor Respondent: Dr. Narendra Kumar Naik
Section 147Section 148Section 148ASection 151Section 151ASection 250(6)

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 ... from the end of the relevant assessment year. The approval before passing the order under Section 148A(d) of the Act and before issuing of notice under Section 148 of the Act has been taken from the Principal Commissioner of Income Tax by the respondent No.1, which is permissible only

Ratan N Motwani (HUF), Mumbai vs. ITO Ward 23(3)(1), Mumbai

In the result, assessee’s appeal is allowed

ITA 5532/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Smt. Beena Pillai & Smt.Renu Jauhri7 (A.Y.2017-18)

For Appellant: Shri. Bhadresh Doshi, CAFor Respondent: Shri Uma Shankar Prasad- CIT
Section 132Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 68

void. 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-19, Mumbai which was not the correct 'specified ... Ashish Agarwal (supra), the notice was treated as show- cause notice issued under section 148A(b) of the 'New Regime. Subsequently an order under section 148A(d) was passed in July 2022. 1.3 The assessee argued that the said notice was for AY 2016-17, the order u/s 148A(d

Income Tax Officer, Income Tax Department, Visakhapatnam vs. Quality Steel Shoppe Private Limited, Visakhapatnam

In the result, the Cross Objection No

ITA 454/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam14 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.454/Viz/2024 ("नधा"रण वष"/Assessment Year: 2018-19) Income Tax Officer, Vs. Quality Steel Shoppe Ward-2(1), Private Limited, Visakhapatnam. Visakhapatnam. Pan: Aaacq1115D (Appellant) (Respondent) C.O. No. 18/Viz/2024 (In आ.अपी.सं /454/Viz/2024) ("नधा"रण वष"/Assessment Year: 2018-19)

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Sri Badicala Yadagiri
Section 144Section 144BSection 147Section 148Section 148ASection 151A

that the AO had grossly erred in law and facts of the case by passing the order under section 148A(d) of the Act, dated 28/04/2022 without the approval of the specified authority as contemplated under section 151 of the Act. Also, we find that the CIT(A) found favour ... 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

Vijaya Kanika, Tirupati vs. Income Tax Officer, Ward-1(3), Tirupati

In the result, the appeal of the assessee is allowed in terms of our above observation

ITA 835/HYD/2025[2016-2017]Status: HeardITAT Hyderabad14 Nov 2025AY 2016-2017

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.835/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Vijaya Kanika Vs. Income Tax Officer Tirupati Ward 1(3) Pan:Dldpk8672K Tirupati (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A Shri E Phalguna Kumar राज" व "ारा/Revenue By: Mr. Rakesh Chintagumpula, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 10/11/2025 घोषणा की तारीख/Pronouncement: 14/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Vijaya Kanika (“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 18.03.2025 For The A.Y 2016-017. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: C.A Shri E Phalguna KumarFor Respondent: Mr. Rakesh Chintagumpula, Sr.DR
Section 144BSection 147Section 148Section 148ASection 151A(1)

merits. In this regards the Ld. AR submitted that the notice under section 148 of the Act and as well as the order under section 148A(d) of the Act were issued by the Jurisdictional Assessing Officer (“JAO”) instead Page 3 of 25 ITA No 835 of 2025 Vijaya Kanika ... which is contrary to the scheme of faceless reassessment introduced by the CBDT. 5. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 23.03.2023 and the notice issued under section 148 of the Act on the same date. He demonstrated that both

Income Tax Officer, Ward-1, Nellore vs. Venkata Ramanamma Sakamuri, Nellore

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed

ITA 482/HYD/2025[2018-19]Status: DisposedITAT Hyderabad14 Nov 2025AY 2018-19

Bench: Us:

Section 147Section 148Section 148ASection 151

then Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. 21. Admittedly, in this case, the approval/sanction for order under section 148A(d) of the Act has been granted by the Principal Commissioner of Income Tax-8. The entire controversy is, therefore, (a) whether the Principal ... whether or not it is a fit case to issue a notice under section 148 of the Act and such an order under section 148A(d) of the Act has to be passed with the prior approval of the specified authority. The Explanation to section 148A of the Act also

Rajbir Singh, Gurgaon vs. ACIT, Central Circle-19, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3104/DEL/2025[2013-14]Status: DisposedITAT Delhi14 Nov 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Rajbir Singh Vs. Acit 1625A, The Magnolia, Dlf Central Circle-19, City, Phase-V, Gurgaon, Khandewalan, Haryana New Delhi Pan: Aaups2176H Appellant Respondent Assessee By Sh. Amarjeet Singh, Ca Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 14/11/2025 Order

Section 13ASection 148Section 148ASection 151Section 29A

virtue of the fourth proviso to Section 149(1) o f the Act, seven days to pass an order under Section 148A(d) o f the A ct (which was necessarily required to accompany a notice under Section 148 of the A c t) . 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

Rushdi Construction Pvt Ltd, Lucknow vs. ITO-5(1), Lucknow

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

ITA 395/LKW/2024[2018-19]Status: DisposedITAT Lucknow13 Nov 2025AY 2018-19

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Suyash Agarwal, AdvocateFor Respondent: Sh. Prajesh Srivastava, Sr. DR
Section 147Section 221

therefore, issued a notice under section 148A(b) but since the assessee did not make any response therefore, he passed an order under section 148A(d) and issued the notice under section 148 on 29.03.2022. In response to the same, the assessee filed a return of income on 28.04.2022. Subsequently

Raju Saha, Barasat, Twenty Four Parganas North vs. DCIT/ACIT, Circle - 61, Kolkata

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

ITA 2056/KOL/2025[2018-2019]Status: DisposedITAT Kolkata13 Nov 2025AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2056/Kol/2025 Assessment Year: 2018-2019 Raju Saha,……………………………….……...……Appellant Swapanapuri, Duttapukur Hatkhola, Barasat, 24-Parganas (N), Kolkata-743248, West Bengal [Pan:Awops1579E] -Vs.- Dcit/Acit,…………………………………….……..Respondent Circle-61, Kolkata, Office Of The Deputy Commissioner Of Income Tax, Bamboo Villa, 169, A.J.C. Bose Road, Kolkata-700014

Section 10Section 142(1)Section 144Section 147Section 148Section 148ASection 192Section 270ASection 80C

Income Tax Act. Accordingly notice under section 148 of the Act was issued to the assesssee after issuance of order under section 148A(d) of the 2 Raju Saha Act with the prior approval of the specified authority, but the assessee did not make any compliance. As the assessee

Guiness Finance & Leasing Pvt. Ltd., Kolkata vs. ITO, Ward 6(2), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1633/KOL/2025[2015-2016]Status: DisposedITAT Kolkata13 Nov 2025AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Guiness Finance & Leasing Pvt. Ltd..….……………….……….……….……Appellant 3Rd Floor, Baid Property, 10, Canning Street, Burra Bazar, Kol-1.. [Pan: Aabck1388B] Vs. Ito, Ward-6(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri Sandeep Lakra, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 16.05.2025 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’). Brief Facts Of The Case Of The Assessee Are That The Assessee 2. Company Filed Its Return Of Income For The A.Y 2015-16 On 30.09.2015 Declaring Total Income Of Rs.Nil. The Said Return Was Selected For Scrutiny On The Reason That The Assessee Is The Beneficiary Of Credit Of Rs.1,28,38,232/- From Penny Stock Company M/S Steel Exchange Ltd. Notices U/S 143(2) & 142(1) Of The Act Were Issued & Thereafter, The Case Of The Assessee Reopened By Issuing Notice U/S 148 Of The Act On 14.07.2022. The Assessing Officer Passed An Ex Parte Order U/S 147 Guiness Finance & Leasing Pvt. Ltd R.W.S. 144B Of The Act On 29.05.2023 Adding Rs.1,28,38,391/- To The Total Income Of The Assessee.

Section 143(2)Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 250

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

Genesis Associates P Ltd, Delhi vs. Assessment Unit, Del-W-()

In the result Assessee’s appeal ITA No

ITA 952/DEL/2024[2013-2014]Status: DisposedITAT Delhi13 Nov 2025AY 2013-2014

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2013-14

Section 139Section 147Section 148Section 69C

issue a notice under Section 148 of the Act. The said notice was required to be accompanied by an order under Section 148A(d) of the Act. Thus, the AO was required to pass an order under Section 148A(d) of the Act within the said twenty-nine days notwithstanding ... Section 149 as amended by the Finance Act, 2021, has become 29.5.2022, whereas the impugned notice under Section 148 along with order under Section 148A(d) of the Act admittedly issued on 28.06.2022 which is found to be barred by limitation and, therefore, the entire proceedings are vitiated and thus

Income Tax Officer, Ward-10(1), I.P Estate vs. Genesis Associates Pvt. Ltd., Kirti Nagar

In the result Assessee’s appeal ITA No

ITA 1084/DEL/2024[2013-14]Status: DisposedITAT Delhi13 Nov 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2013-14

Section 139Section 147Section 148Section 69C

issue a notice under Section 148 of the Act. The said notice was required to be accompanied by an order under Section 148A(d) of the Act. Thus, the AO was required to pass an order under Section 148A(d) of the Act within the said twenty-nine days notwithstanding ... Section 149 as amended by the Finance Act, 2021, has become 29.5.2022, whereas the impugned notice under Section 148 along with order under Section 148A(d) of the Act admittedly issued on 28.06.2022 which is found to be barred by limitation and, therefore, the entire proceedings are vitiated and thus

Income Tax Officer 17(1)(1), Mumbai vs. Ashok Amritlal Nayak, Mumbai

In the result, appeal of the revenue is dismissed and the C

ITA 3484/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Surendra Mohan, Sr. DRFor Respondent: Shri Rahul Hakani, AR
Section 115BSection 143(1)Section 148Section 151ASection 250Section 68

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

Lumar Gems, Mumbai vs. ACIT Circle 23(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 3450/MUM/2025[2018-19]Status: DisposedITAT Mumbai11 Nov 2025AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr. DR
Section 147Section 148Section 148ASection 151Section 250Section 68Section 69C

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

Pentyala Madhavi, Hyderabad vs. Income Tax Officer, Ward-12(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 392/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad07 Nov 2025AY 2015-2016

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

Section 139Section 142(1)Section 144Section 147Section 148Section 69A

reopened the assessment as per the amended provisions of Section 148A of the Income Tax Act, 1961, after passing the necessary order under Section 148A(d) of the Act. According to the A.O., the income chargeable to tax, represented in the form of asset, which is likely to exceed