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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)

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1566/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha G.आ. अपी.सं / Ita Nos.1566 & 1571/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2020-21 & 2021-22) M/S. Exel Rubber Private Ltd Vs. Hyderabad Dy.Cit Central Circle 1 (2) Hyderabad Pan:Aaace4495J (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri M.V. Prasad, Ca राजस्व द्वारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख / Date Of Hearing: 20/01/2026 घोषणा की तारीख / Pronouncement: 18/02/2026 Per Manjunatha, G. A.M. आदेश/Order These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-11, Hyderabad, Both Dated 14/07/2025 For The A.Ys 2020-21, 2021-22 & 2022-23 Respectively. Since Common Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)
Section 132Section 132(4)Section 143(3)Section 148

that there is any material before him to treat it as a fit case to issue notice under section 148 or pass order under section 148A(d). The safeguards provided in sections 148 and 151 were lightly treated by the Asstt. Commissioner and the Pr. Commissioner. Both of them appear

Darshana Jatin Shah, Mumbai vs. ITO Ward 19(1)(1), Mumbai

The appeal of the assessee is allowed

ITA 7769/MUM/2025[2015-16]Status: DisposedITAT Mumbai18 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 139(1)Section 144Section 147Section 148Section 148ASection 151Section 151ASection 250Section 69Section 69A

assessee raised legal as well as factual grounds. The assessee contended that notices under sections 148A(b), 148 and order under section 148A(d) were not validly served and therefore the reassessment proceedings were vitiated for want of proper service. It was also contended that the notice under section

Harleen Kaur Ghura, Mumbai vs. ITO Ward 28(1)(1), Mumbai

In the result appeal filed by the assessee is allowed

ITA 7664/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarharleen Kaur Ghura Vs. Ito, Ward 28(1)(1), B 602 Ambe Prerna, Sector Mumbai 3, Ghansoli, It-Office, Vasi Railway Navi Mumbai- 400701, Station Building, Navi Mumbai - 400703 Pan/Gir No. Aovpg9346L (Applicant) (Respondent)

Section 148Section 148ASection 151Section 151ASection 250Section 69

Ghura “1. On the facts and circumstances of the case and in law, the Ld. 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

Sri Pratap Chandra Tripathy, Ganjam vs. ITO, Ward-1, Ganjam

In the result, appeal of the assessee stands allowed

ITA 731/CTK/2025[2016-17]Status: DisposedITAT Cuttack17 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Madhusudan Sawdiaआयकर अपील सं/Ita No.731/Ctk/2025 ("नधा"रण वष" / Assessment Years : 2016-2017) Vs Ito, Ward-1, Berhampmur, Ganjam Sri Pratap Chandra Tripathy, Braja Nagar, 1St Lane, Lochapada Road, Berhampur, Ganjam-760001 Pan No. :Acfpt 5072 J (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri S.K.Sarangi, Ar राज"व क" ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 17/02/2026 घोषणा क" तार"ख/Date Of Pronouncement : 17/02/2026

For Appellant: Shri S.K.Sarangi, ARFor Respondent: Shri Vijay Singh, 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

Sri Nikhil Maheswari, Kolkata vs. I.T.O., Ward - 50(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1786/KOL/2025[2010-2011]Status: DisposedITAT Kolkata17 Feb 2026AY 2010-2011

Bench: Shri Rajesh Kumar, Am Sri Nikhil Maheswari Bf-250, 2Nd Floor, Sector-1, Ito Ward 50(1) Central Circle-Block, Uttrapan Complex, Manicktalla Baisakhi Island Sali, Salt Lake, Civil Centre, Ultadanga, Kolkata- Vs. Bidhannagar, Kolkata-700064, 700054, West Bengal West Bengal (Appellant) (Respondent) Pan No. Bbzpm1050R Assessee By : Shri Abhishek Bansal, Ar Revenue By : Shri Pampa Ray, Dr Date Of Hearing: 29.01.2026 Date Of Pronouncement: 17.02.2026

For Appellant: Shri Abhishek Bansal, ARFor Respondent: Shri Pampa Ray, DR
Section 142(1)Section 143(1)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.” 7.2. Similarly, in the case of Haresh kumar Dungarmal

Kathirvelu Subbarayan, Chennai vs. ITO, Ncw-19(4), Chennai

The appeal of the assessee is allowed for statistical purposes

ITA 3854/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Feb 2026AY 2020-21

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3854/Chny/2025 िनधा"रण वष" /Assessment Year: 2020-21

For Appellant: Mr. Subash Anbaraju.K, Advocate
Section 148Section 148ASection 249Section 249(4)Section 250

assessing officer issued the notice under section 148A(b) on 03.02. 2024. Kathirvelu Subarayan :- 2 -: The assessing officer subsequently passed an order under section 148A(d) on 28.03.2024 and also reopened the assessment by issuing notice under section 148 of the act. Since the assessee did not respond

Aman Gupta, Chennai vs. Deputy Commissioner of Income Tax, Circle - 1, Ltu Chennai, Chennai

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

ITA 2565/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Feb 2026AY 2016-17

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2565/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Shri Aman Gupta, The Deputy Commissioner A-1, Vrindavan Enclave, Vs. Of Income Tax, 189, Lloyds Road, Circle 1, Gopalapuram, Ltu, Chennai – 600 086. Chennai. Pan: Adzpa 0417D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri V. Tharish, Ca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 17.02.2026

For Appellant: Shri V. Tharish, CAFor Respondent: Ms. Gouthami Manivasagam
Section 147ASection 148Section 148ASection 250Section 69A

show-cause notice under section 148A(b). After following the due procedure under section 148A (including issuance of show-cause notice and order under section 148A(d) dated 30.07.2022), the fresh notice under section 148 was issued on the same date (30.07.2022) by the Jurisdictional Assessing Officer. 24. These jurisdictional ... assessee fully participated throughout the reassessment proceedings right from the deemed show-cause notice under section 148A(b), the order under section 148A(d), the fresh notice under section 148 dated 30.07.2022, and the entire assessment proceedings culminating in the order dated 23.05.2023 without raising even a whisper about

ACIT22(1), Mumbai vs. Spr Associates, Mumbai

In the result, the appeal filed by the revenue stands dismissed and the cross-objection filed by assessee stands allowed

ITA 6562/MUM/2025[2018]Status: DisposedITAT Mumbai17 Feb 2026

Bench: Smt. Beena Pillai () & Shri Arun Khodpia, ()

Section 147Section 148Section 148ASection 68

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 ... required to obtain prior approval of the specified authority u/s 151 of the Act under the new regime before passing an order under section 148A(d) and issuing a notice u/s 148 of the Act. 5.3. The appropriate authority who could sanction the said notice, issued beyond a period

Choday Janaki Ramayya Chowdary, Visakhapatnam vs. Income Tax Officer, Ward-1, Kakinada

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

ITA 623/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam16 Feb 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble

Section 147Section 148Section 148ASection 69A

treated as his undisclosed income. As the assessee has failed to respond to the aforesaid notice, therefore, the AO passed an order under section 148A(d) of the Act, dated 31.03.2022. Thereafter, the AO issued a notice under section 148 of the Act, dated 02.04.02022, wherein the assessee was called ... submitted that the time spent from the issuance of notice under section 148A(b) of the Act upto the passing of the order under section 148A(d) of the Act in terms of “fifth proviso” and “sixth proviso” cannot be excluded for reckoning the limitation period for issuance of notice

Ashok Narayan Satav, Pune vs. Income Tax Officer. Ward 12(3), Pune

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

ITA 3355/PUN/2025[2017-18]Status: DisposedITAT Pune16 Feb 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3355/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Ashok Narayan Satav, V The Income Tax Near Datta Mandir, Wadjai, S Officer, Ward-12(3), Wagholi, Haveli, Pune. Pune – 412207. Pan: Aypps9425G Appellant/ Assessee Respondent /Revenue Assessee By Shri Deepak S Sasar Revenue By Shri Sadananda – Jcit(Dr) Date Of Hearing 12/12/2026 Date Of Pronouncement 16/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 29.10.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The I.T.Act, Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Hon. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre Has Wrongly Confirmed The Addition Made By

Section 115BSection 139Section 144Section 147Section 148Section 148ASection 250Section 251(1)(a)Section 69C

ld.CIT(A) to ld.CIT(A) for denovo adjudication. Ld.CIT(A) shall call from the Assessing Officer copies of the notice u/s.148A(b), order under section 148A(d) of the Act, to verify the facts. Ld.CIT(A) shall also provide opportunity to the Assessee. Assessee shall file necessary details before

Adarsh Developers, Mumbai vs. ITO, Ward 22(3)(1), Mumbai

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

ITA 7945/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 147Section 148Section 148ASection 151Section 151ASection 50CSection 50C(2)

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 ... required to obtain prior approval of the specified authority u/s 151 of the Act under the new regime before passing an order under section 148A(d) and issuing a notice u/s 148 of the Act. 5.3. The appropriate authority who could sanction the said notice, issued beyond a period

Surya Pratap Singh Chauhan, Lucknow vs. The Income Tax Officer, Ward-2(1), Lucknow

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

ITA 642/LKW/2025[2018-19]Status: DisposedITAT Lucknow13 Feb 2026AY 2018-19

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2018-19 Surya Pratap Singh Chauhan, Vs. The Income Tax Officer, Ward- 68/422, Gandhi Nagar, Lucknow- 2(1), Lucknow-New 226001 Pan: Awgpc6261P (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Smt. Sonal Singh, Jcit Dr Date Of Hearing: 01.12.2025 Date Of Pronouncement: 13.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac, Dated 7.07.2025 Wherein The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee That Were Filed Against The Assessment Order Passed By The Assessment Unit For The A.Y. 2018-19 Under Section 147 R.W.S. 144 On 3.03.2023. The Grounds Of Appeal Are As Under:- “01. Because The Notice Issued Under Section 148 Has Been Issued By The Jao, Which Is Contrary To The Provisions Of Section 151A Of The Act, The Entire Assessment Framed Is Bad In Law Be Quashed. 02. Because The Notice Under Section 148 Having Been Issued On 23.03.2022, Beyond The Period Of Three Years & The Total Investment In Bit Coin Trading Is Of Rs.9,63,000/-, There Being No Profit On The Same On The Contrary Being Loss, The Entire Reopening Of The Assessment Is Without Proper Verification Of Facts, Based On Wrong Facts The Addition Of Rs.88,55,128/- Made By The Ao & Upheld By The Cit(A) Be Deleted. 03. Because The Cit(A), Nfac, Has Failed To Appreciate The Facts & Circumstances Of The Case & Has Arbitrarily Upheld The Addition Of Rs.88,55,128/- Under Section 69 Of The Income-Tax Act, 1961 Being Unexplained Investment In Purchase & Sale Of Bitcoins, Which Addition Is Contrary To Facts, Bad In Law, The Addition Made Be Deleted.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Smt. Sonal Singh, JCIT DR
Section 139Section 143(2)Section 147Section 148Section 148ASection 151ASection 69

amounting to Rs. 83,78,124/-. Accordingly, after giving due opportunity of being heard under section 148A(b) of the Act, an order under section 148A(d) of the Act was passed on 29.03.2022 and subsequently notice under section 148 was issued on 30.03.2022. In response,the assessee filed ... appeal contesting the validity of the reopening and Sh. Rakesh Garg, Advocate (hereinafter referred to as ld. AR) pointed out that the order under section 148A(d) was itself wrong because the assessee had filed a reply before ITO-2(1) on 31.03.2022 in response to the notice under section

Power Security Corp. Pvt. Ltd., Chennai vs. ITO, Corp. Ward-5(2), Chennai

The appeal of the assessee is allowed

ITA 2943/CHNY/2025[2013-14]Status: DisposedITAT Chennai13 Feb 2026AY 2013-14

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2943/Chny/2025 िनधा$रण वष$ /Assessment Year: 2013-14

For Appellant: Mr. Y. Sridhar, C.A ()For Respondent: Ms. R. Anitha, Addl. CIT
Section 144Section 147Section 148Section 148ASection 149Section 154Section 250

response within the time specified or the time expired where the assessee has not filed any reply; (iii) The AO passes an order under section 148A(d) within 30 days from the end of the month in which the reply is received by the AO or the time given

DCIT Central Circle- 7(1), Mumbai vs. Bhavik Prafulchandra Vora, Gujrat

In the result, the appeal filed by the revenue is dismissed and cross-objection filed by assessee is partly allowed

ITA 7602/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 151Section 151ASection 68

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 ... required to obtain prior approval of the specified authority u/s 151 of the Act under the new regime before passing an order under section 148A(d) and issuing a notice u/s 148 of the Act. 5.3. It is noted that in the new regime, if the income escaping assessment

DCIT Central Circle- 7(1), Mumbai vs. Pranavkumar Prafulchandra Vora, Gujrat

In the result, the appeal filed by the revenue is dismissed and cross-objection filed by assessee is partly allowed

ITA 7596/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 147Section 148Section 151ASection 68

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 ... required to obtain prior approval of the specified authority u/s 151 of the Act under the new regime before passing an order under section 148A(d) and issuing a notice u/s 148 of the Act. 5.3. It is noted that in the new regime, if the income escaping assessment

Surat Goods Transport Pvt Ltd, Mumbai vs. DCIT Circle 16(2), Mumbai

ITA 7556/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Feb 2026AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

Section 143(3)Section 144Section 144BSection 147Section 148Section 148ASection 154Section 68

return of income of the assessee. Further, reassessment proceedings were initiated against the assessee under section 148 of the Act and the order under section 148A(d) was passed on 07.04.2022. The reassessment proceedings are completed by the ld. AO, making an addition of Rs. 5,04,493/-, being interest ... notice under section 148 of the Act. 9. In view of such facts and circumstances, the notice under section 148, the order under section 148A(d) and the consequential proceedings thereafter has no standing in the eyes of law, we thus respectfully following the decision of Hon’ble Bombay High

Dattatray Vithoba Sawant, Kalyan vs. Income Tax Officer, WD-42(2)(2), Mumbai

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

ITA 6081/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 10(14)Section 133ASection 142(1)Section 148Section 148ASection 151Section 151ASection 3Section 80CSection 80G

obtain prior approval of the 9 I.T.A. No. 6081/Mum/2025 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 ... required to obtain prior approval of the specified authority u/s 151 of the Act under the new regime before passing an order under section 148A(d) and issuing a notice u/s 148 of the Act. 10 I.T.A. No. 6081/Mum/2025 5.3. It is noted that in the new regime

Prabhulal Kalji Doshi, Mumbai vs. ITO Ward 19(2)(4), Mumbai

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

ITA 7421/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 148ASection 151Section 68

obtain prior approval of the 14 I.T.A. No. 7421/Mum/2025 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 ... required to obtain prior approval of the specified authority u/s 151 of the Act under the new regime before passing an order under section 148A(d) and issuing a notice u/s 148 of the Act. 15 I.T.A. No. 7421/Mum/2025 5.3. It is noted that in the new regime

Impressive Trading Private Limited, Mumbai vs. Income Tax Officer 10(1)(1), Mumbai

In the result, all the above appeals in ITA Nos

ITA 7300/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Feb 2026AY 2015-16

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)
Section 147Section 147oSection 148Section 148ASection 151A

case that since he was travelling during such time, he could not file any reply. 8. On 25.07.2022, Respondent No.1 passed an order under Section 148A(d) of the Act. In absence of any reply of the Petitioner, Respondent No.1 stated that it is a fit case to issue notice ... Being aggrieved by this action, the Petitioner filed a Writ Petition, inter alia, challenging the said notice under Section 148 and the order under Section 148A(d) of the Act which was lodged as WP(L)No.2907 of 2023. This Writ Petition was disposed of vide order dated

Impressive Trading Private Limited, Mumbai vs. Income Tax Officer 10(1)(1), Mumbai

In the result, all the above appeals in ITA Nos

ITA 7299/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Feb 2026AY 2014-15

Bench: Shri Narendra Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Virabhadra S. Mahajan, (Sr. DR)
Section 147Section 147oSection 148Section 148ASection 151A

case that since he was travelling during such time, he could not file any reply. 8. On 25.07.2022, Respondent No.1 passed an order under Section 148A(d) of the Act. In absence of any reply of the Petitioner, Respondent No.1 stated that it is a fit case to issue notice ... Being aggrieved by this action, the Petitioner filed a Writ Petition, inter alia, challenging the said notice under Section 148 and the order under Section 148A(d) of the Act which was lodged as WP(L)No.2907 of 2023. This Writ Petition was disposed of vide order dated