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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)

Dinesh Dilip Mehta, Pune vs. Income Tax Officer, Ward-7(1), Pune

In the result, appeal of the assessee is partly allowed

ITA 2048/PUN/2024[2017-18]Status: DisposedITAT Pune30 Apr 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2048/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Dinesh Dilip Mehta, V The Income Tax Officer, 936 3, Irvin Road, New Nana S Ward-7(1), Pune. Peth, Opp.M Phule High School, Pune – 411002. Pan: Abbpm0414G Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak – Ar Revenue By Shri Vidya Ratna Kishor - Dr Date Of Hearing 25/03/2025 Date Of Pronouncement 30/04/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: Thisappeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961; Dated 01.08.2024For Assessment Year2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “1] The Learned Cit(A) Erred In Confirming An Addition Of Rs.69,10,300/- On Account Of Alleged Commission Income U/S 56 Of The Act.

Section 147Section 148Section 148ASection 151Section 250Section 56

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 ... Developers (P.) Ltd, Vs. ITO [2024] 159 taxmann.com 178 (Bombay) dated 29.01.2024 has held as under : Quote “1. Petitioner is impugning a order under section 148A(d) and the notice, both dated 7th April 2022 passed under section 148 of the Income Tax Act, 1961 ("Act"). Of-course Petitioner

Srinivasan Varatharaj, Chennai vs. ACIT, Ncw-10(1), Chennai

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

ITA 579/CHNY/2025[2017-18]Status: DisposedITAT Chennai30 Apr 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.579/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Srinivasan Varatharaj, Vs. The Assistant Commissioner Of 11, Kandan Street, Perambur S.O., Income Tax, Perambur, Chennai 600 011. Non Corporate Ward 10(1), Chennai 600 034. [Pan:Avjps1866L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri Sricharan, Ca & : Ms. Srinithi, Advocate For Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri M.P. Guru Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 22.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 08.11.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 27 Days. The Assessee Filed A Petition For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Petition, We

For Respondent: Shri M.P. Guru Prasad, Addl. CIT
Section 142(1)Section 148Section 148ASection 194ISection 69

made cash deposits of ₹.4,58,30,000/- during demonetization period in bank account maintained with the Indian Bank. Accordingly, after passing order under section 148A(d) of the Income Tax Act, 1961 [“Act” in short], the Assessing Officer issued notice under section 148 of the Act, besides, issuing notices

Devalbai Karsan Parmar, Mumbai vs. Income Tax Officer Ward 20(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1786/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Apr 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2017-18 Devalbai Karsan Parmar, Income Tax Officer, Ward-20(1)(1), H9, B-401, Herumb Chs, 3Rd Floor, New Mhada Colony, Vs. Piramal Chambers, Kamgar Nagar, Lalbaugh, Near Tilak Nagar Mumbai-400012. Railway Station, Chembur, Mumbai-400024. Pan: Aispp0021A (Appellant) (Respondent) For Assessee : Shri Shashank Mehta For Revenue : Shri Asif Karmali, Sr.Dr

For Appellant: Shri Shashank MehtaFor Respondent: Shri Asif Karmali, Sr.DR
Section 147Section 148Section 148ASection 151Section 151ASection 56Section 56(2)Section 56(2)(vii)

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

Bio- Care Technologies, Mumbai vs. ITO, Ward 32(1)(1), Mumbai

In the result, ground No. 4 of the appeal is partly allowed

ITA 6946/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 Apr 2025AY 2018-19

Bench: Shri Pawan Singh, Hon'Ble

Section 142Section 148Section 148ASection 234ASection 254(1)Section 50CSection 56(2)(x)

issue. The Assessing Officer recorded that assessee has offered no explanation within the time allowed in the notice. The Assessing Officer passed order under section 148A(d) of the Act on 06.04.2022 and simultaneously issued notice under section 148 dated 06.04.2022 of the Act on same day after recording reasons ... sold such property; rather the assessee had purchased the property. Thus, the basis of reopening is itself wrong. Thus, Assessing Officer passed order under section 148A(d) without verification of facts. Once the basis of issuance of notice itself is wrong the action thereon is void ab-initio. The assessee

Kai Ganpatrao Sakharam Pawar Nagari Sahakari Patsanstha, Maryadit, Karad vs. ITO, Ward-1, Satara

In the result, appeal of the assessee is partly allowed

ITA 356/PUN/2025[2017-18]Status: DisposedITAT Pune29 Apr 2025AY 2017-18

Bench: DR. DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 147Section 148Section 148ASection 151Section 250Section 69A

Developers (P.) Ltd, Vs. ITO [2024] 159 taxmann.com 178 (Bombay) dated 29.01.2024 has held as under : Quote “1. Petitioner is impugning a order under section 148A(d) and the notice, both dated 7th April 2022 passed under section 148 of the Income Tax Act, 1961 ("Act"). Of-course Petitioner ... A.Y.2018-19. 6. In the above referred decision of Hon’ble Bombay High Court, the assessment year involved is A.Y.2018-19 and order udder section 148A(d) of the Act, was passed on 07.04.2022. In the case of the assessee, Kai Ganpatrao Sakharam Pawar Nagari Sahakari Patsnastha, the assessment year is A.Y.2017-18

Emerald Alchymicus Private Limited, Mumbai vs. DCIT, Circle 15(1)(1), Mumbai

In the result, above captioned appeals filed by the assessee are allowed for statistical purposes

ITA 1424/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Apr 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Sri Pankaj Soni, Adv a/w Ms. S. Shanmugam,ARsFor Respondent: Sri Biswanath Das, (CIT DR)
Section 147Section 148Section 148ASection 14ASection 270ASection 68Section 69A

that the reopening of the assessment proceeding in case of the appellant under section 147, issuing notice under section 148, and passing order under section 148A(d) of the Act is invalid, without jurisdiction, perverse, arbitrary and bad in law. 3. That the CIT(A) erred in law and fact ... that the reopening of the assessment proceeding in case of the appellant under section 147, issuing notice under section 148, and passing order under section 148A(d) of the Act is invalid, without jurisdiction, perverse, arbitrary and bad in law. 3. That the CIT(A) erred in law and fact

Emerald Alchymicus Private Limited, Mumbai vs. DCIT, Circle 15(1)(1), Mumbai

In the result, above captioned appeals filed by the assessee are allowed for statistical purposes

ITA 1423/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Apr 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Sri Pankaj Soni, Adv a/w Ms. S. Shanmugam,ARsFor Respondent: Sri Biswanath Das, (CIT DR)
Section 147Section 148Section 148ASection 14ASection 270ASection 68Section 69A

that the reopening of the assessment proceeding in case of the appellant under section 147, issuing notice under section 148, and passing order under section 148A(d) of the Act is invalid, without jurisdiction, perverse, arbitrary and bad in law. 3. That the CIT(A) erred in law and fact ... that the reopening of the assessment proceeding in case of the appellant under section 147, issuing notice under section 148, and passing order under section 148A(d) of the Act is invalid, without jurisdiction, perverse, arbitrary and bad in law. 3. That the CIT(A) erred in law and fact

Emerald Alchymicus Private Limited, Mumbai vs. DCIT, Circle 15(1)(1), Mumbai

In the result, above captioned appeals filed by the assessee are allowed for statistical purposes

ITA 1422/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Apr 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Sri Pankaj Soni, Adv a/w Ms. S. Shanmugam,ARsFor Respondent: Sri Biswanath Das, (CIT DR)
Section 147Section 148Section 148ASection 14ASection 270ASection 68Section 69A

that the reopening of the assessment proceeding in case of the appellant under section 147, issuing notice under section 148, and passing order under section 148A(d) of the Act is invalid, without jurisdiction, perverse, arbitrary and bad in law. 3. That the CIT(A) erred in law and fact ... that the reopening of the assessment proceeding in case of the appellant under section 147, issuing notice under section 148, and passing order under section 148A(d) of the Act is invalid, without jurisdiction, perverse, arbitrary and bad in law. 3. That the CIT(A) erred in law and fact

Mr Rahat Mohammed Riyazuddin Shaikh, Mumbai vs. Income Tax Officer NFAC, Mumbai

In the result, appeal of the assessee is allowed

ITA 5291/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Apr 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Ajay Singh, Advocate and Shri Akshay Pawar, ARFor Respondent: R. R. Makwana, Addl. CIT
Section 147Section 148Section 148ASection 151Section 151(1)Section 50CSection 56(2)Section 56(2)(vii)

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

ACIT Circle - 22(1), Mumbai vs. Nilesh Haresh Parwani, Mumbai

In the result, the Cross Objection by the assessee is allowed, while the Revenue’s appeal is dismissed

ITA 266/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Apr 2025AY 2015-16

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Paresh Deshpande, Sr. DR
Section 133ASection 250

terms of the provisions of section 148A(b) of the Act. 8. After rejecting the objections filed by the assessee, an order under section 148A(d) of the Act was passed on 23.07.2022, declaring that it is a fit case for the issuance of a notice under section

Income Tax Officer, Mumbai vs. Uttamchand Rajmal Jain, Mumbai

In the result the cross objection filed by the assessee stands allowed in terms of grounds 2, 5 and 7 and the appeal filed by the revenue stands dismissed

ITA 4714/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Apr 2025AY 2016-17

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 147Section 148Section 151Section 69A

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

Mukesh Kumar Bhawarlal Jain, Mumbai vs. ITO, WD 23(2)6, Mumbai

In the result, additional ground no

ITA 6745/MUM/2024[2016-17]Status: DisposedITAT Mumbai23 Apr 2025AY 2016-17
Section 144BSection 147Section 148Section 148ASection 151Section 250Section 254(1)Section 69A

from the end of relevant assessment years. Admittedly the escaped income is less than Rs.50,00,000/-. Such fact in mentioned in order under section 148A(d) dated 27.07.2022, Thus, as per amended provision, the approval of reasons recorded should have been obtained from Principle Chief Commissioner of Income ... PCCIT). However, as per order under section 148A(d) such approval was given by Pr. CIT-19. Thus, the approval was not obtained in accordance with provision of section 151(ii) of the Act. Therefore, action initiated in the basis of invalid notice under section 148 is void ab initio

Mr. Viren Rohitkumar Shah, Mumbai vs. ITO Ward 32(2)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 90/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Apr 2025AY 2016-17

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalmr. Viren Rohitkumar Shah, 02/009 Om Heera Pana Mall, Oshiwara, Andheri (W), Mumbai - 400102 ............... Appellant Pan : Aaqps2809B V/S

For Appellant: Shri Hitesh JainFor Respondent: Ms. Kavitha Kaushik, Sr.DR
Section 147Section 148Section 148ASection 151Section 234BSection 250Section 271(1)(c)Section 69

terms of the provisions of section 148A(b) of the Act. 9. After rejecting the objections filed by the assessee, an order under section 148A(d) of the Act was passed on 31/07/2022 declaring that it is a fit 5 case for issuance of notice under section

Vividhodhesha Prathamika Gramina Krushi Sahakara Sangha Ni Gejjalagere, Mandya vs. Income Tax Officer, Ward-1 & Tps, Mandya

In the result appeal of the assessee is partly allowed

ITA 2071/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmedassessment Year: 2018-19

For Appellant: Shri Tarun Kothari, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 147Section 148Section 151Section 254Section 80P

Petitioner in the reply to the show cause notice. 10. We also found in the said guidelines a provision that the order under section 148A(d) of the Act shall be sent to assessee along with the approval of the specified authority for such order under section 148A(d ... find that failure to afford a reasonable opportunity of being heard under section 148A(b) of the Act, prior to passing the order under section 148A(d) of the Act and issuing the consequential notice under section 148 of the Act, constitutes a violation of mandatory . Page

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR
Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

petitioner. 3.3 The petitioner filed a reply dated 14-6-2022 qua the said notice. 3.4 Thereafter, the revenue passed an order under section 148A (d) of the Act dated 29-7-2022 holding that income amounting to Rs. 4,37,56,000/-had escaped assessment. A consequential notice ... date i.e., 29-7-2022 was also issued to the petitioner under section 148 of the Act. 3.5 A perusal of the order under section 148A (d) and the notice under section 148 would show that they have been passed/issued after obtaining the prior approval of the Principal Commissioner

E Ashwath Narayan, Bangalore vs. Income Tax Officer, Ward-3(3)(1), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 1920/BANG/2024[2015-16]Status: DisposedITAT Bangalore17 Apr 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri S. Satish, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)Section 250Section 69A

Petitioner in the reply to the show cause notice. 10. We also found in the said guidelines a provision that the order under section 148A(d) of the Act shall be sent to assessee along with the approval of the specified authority for such order under section 148A(d

Stc Securities Private Limited, Mumbai vs. Assessment Unit Income Tax Department, Mumbai

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

ITA 82/MUM/2025[2016-17]Status: DisposedITAT Mumbai16 Apr 2025AY 2016-17

Bench: Shri Sandeep Gosain & Smt. Renu Jauhri

Section 148Section 148ASection 149(1)Section 149(1)(b)Section 250

case of Ashish Agrawal (supra), the said notice was deemed as notice issued under section 148A(b). The AO after passing the order under section 148A(d) issued the notice under section 148 dated 29.07.2022. The contention of the assessee is that the said notice is barred by limitation

Stc Securities Private Limited, Mumbai vs. Assessment Unit Incoem Tax Department, Mumbai

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

ITA 81/MUM/2025[2015-16]Status: DisposedITAT Mumbai16 Apr 2025AY 2015-16

Bench: Shri Sandeep Gosain & Smt. Renu Jauhri

Section 148Section 148ASection 149(1)Section 149(1)(b)Section 250

case of Ashish Agrawal (supra), the said notice was deemed as notice issued under section 148A(b). The AO after passing the order under section 148A(d) issued the notice under section 148 dated 29.07.2022. The contention of the assessee is that the said notice is barred by limitation

Lalit Surajprakash Garg, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, the appeals in ITA 6125/Mum/2024 (A

ITA 6126/MUM/2024[2017-18]Status: DisposedITAT Mumbai15 Apr 2025AY 2017-18

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Gaurav Bansal,CAFor Respondent: Shri Ram Krishn Kedia (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 149(1)

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...” 18. In the course of hearing before us, the ld.DR relied on the orders of authorities

Lalit Surajprakash Garg, Mumbai vs. DCIT, Central Circle-6(2), Mumbai

In the result, the appeals in ITA 6125/Mum/2024 (A

ITA 6125/MUM/2024[2016-17]Status: DisposedITAT Mumbai15 Apr 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Gaurav Bansal,CAFor Respondent: Shri Ram Krishn Kedia (Sr. DR)
Section 144BSection 147Section 148Section 148ASection 149(1)

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...” 18. In the course of hearing before us, the ld.DR relied on the orders of authorities