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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)

Govind Mansharam Dingwa, Mumbai vs. Income Tax Officer - 22(1)(1), Mumbai

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

ITA 5019/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jan 2026AY 2015-16

Bench: Shri Sandeep Gosain

Section 147Section 148Section 148ASection 250Section 69A

account of limitation, as the amount was less than Rs. 50 lacs. [Para 22] However, the Assessing Officer while passing the order under section 148A(d) in a wholly mechanical manner rejected the plea of the assessee and proceeded to issue notice under section 148. Whereafter proceedings were sought ... account of limitation, as the amount was less than Rs. 50 lacs. [Para 22] However, the Assessing Officer while passing the order under section 148A(d) in a wholly mechanical manner rejected the plea of the assessee and proceeded to issue notice under section 148. Whereafter proceedings were sought

Navgrahaa Jewels Private Limited, Mumbai vs. Deputy Commissioner, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4786/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jan 2026AY 2013-14

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarnavgrahaa Jewels Private Ltd. Vs Deputy Commissioner 7(1)(1), Unit No.341 & 342, Pragati Mumbai Industrial Esrate, N. M. Joshi Aayakar Bhawan, Mumbai-400020 Marg, Lower Parel East, Mumbai-400011 Pan: Aaecn0220G Appellant Respondent Assessee By : Shri Dharan Gandhi, Adv., Ms. Vinita Nara Adv Respondent By : Shri Leyaqat Ali Aafaqui, Sr Dr Date Of Hearing : 28/01/2026 Date Of Pronouncement : 30/01/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Nfac, Delhi [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2013-14, Date Of Order 11.11.2024. The Impugned Order Emanated From The Order Of The Assessment

For Appellant: Shri Dharan Gandhi, Adv., Ms. Vinita Nara AdvFor Respondent: Shri Leyaqat Ali Aafaqui, SR DR
Section 14Section 147Section 148Section 148ASection 14bSection 250Section 69C

notices issued between April 1, 2021, and June 30, 2021, were deemed as show-cause notices under Section 148A(b). Accordingly,an order under Section 148A(d) was passed on July 29, 2022, after providing opportunity, and a fresh notice under Section 148 was issued on the same date

Galax Minerals (P) Ltd., Haryana vs. Income Tax Officer 10(1), New Delhi, Delhi

The appeal of the assessee is allowed

ITA 2894/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalm/S Galax Minerals (P)Ld. Vs. Income Tax Officer 591, 2Nd Floor, Udyog Ward-10(1) Vihar, Phase-V, Industrial New Delhi Complex Dundahera, Gurugram, 122016 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcg7346K Appellant .. Respondent

For Appellant: Sh. Lalit Mohan, CAFor Respondent: Ms. Pooja Swaroop, CIT, DR
Section 147Section 148Section 148ASection 151

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

Anumita Infrastructure Private Limited, Mumbai vs. PCIT-4, Mumbai

ITA 2555/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Jan 2026AY 2017-18

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar

Section 139(4)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 151Section 151ASection 263

section 148A(a); ii. while providing opportunity of being heard to the assessee under section 148A(b); iii. prior to passing of order under section 148A(d); and iv. prior to issuance of notice under section 148 of the Act. 11.1. The learned AR invited attention to the factual matrix ... Assessing Officer in the assessee's case. It was pointed out that: Sr. No. Particulars Date Observations 1. Approval for passing of order under section 148A(d) of the Act 26.07.2022 Approval obtained prior to passing of order under section 148A(d) 2. Order passed under section 148A(d

Peda Subba Rao Unnam, Addanki vs. ITO, Ward-1, Ongole

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

ITA 1664/HYD/2025[2015-16]Status: DisposedITAT Hyderabad28 Jan 2026AY 2015-16

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

Section 147Section 148Section 149Section 149(1)(a)Section 69A

notice under Section 148 of the Act should not be issued. As no reply was received, the A.O. passed an order under Section 148A(d) of the Act on 06.04.2022 and thereafter, issued notice under Section 148 of the Act on the same date. In response to notice issued under ... supra), the said notice was deemed as notice issued under section 148A(b). The AO 17 Peda Subba Rao 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

Sudesh Dhanraj Murpana (HUF), Mumbai vs. The Income Tax Officer, Ward 23(3)(1, Mumbai

In the result, appeal of the assessee is allowed

ITA 5485/MUM/2025[2013-14]Status: DisposedITAT Mumbai28 Jan 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Sudesh Dhanraj Murpana Income Tax Officer – 23(3) (1) (Huf) Matru Mandir, Tardeo, Grant 401 Somdhan Bldg, Perry Road, Cross Road Bandra (West), Vs. Mumbai - 400007 Mumbai 400050

For Appellant: Shri Mahavir Jain and Shobit MishraFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 147Section 148Section 68

taking up this reassessment proceedings, notice under section 148A(b) was issued on 18.06.2022, for which order under section 148A(d) was passed on 20.07.2022. Subsequently, notice under section 148 was issued on 20.07.2022. Computation of limitation as per decision of, Hon’ble Supreme Court in the case

Rajput Mohammadmuntasim Tashbihuddin, Delhi vs. Income Tax Officer, Delhi

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

ITA 3958/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh

Section 139(1)Section 142(1)Section 147Section 272A(1)(d)Section 69A

stipulated time despite due service of notice through the e-proceedings portal. In view of the assessee's non-compliance, the order under section 148A(d) dated 30.03.2022 was passed after due consideration of the material available on record and with the prior approval of the specified authority. Consequently

Sunil Kumar Singh, New Delhi vs. Income Tax Officer, Ward 60(5), Delhi, New Delhi

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

ITA 3657/DEL/2025[2013-14]Status: DisposedITAT Delhi28 Jan 2026AY 2013-14

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarsunil Kumar Singh, Vs. Income Tax Officer, S-172B, Pandav Nagar, Ward 60 (5), Delhi. Laxmi Nagar, Delhi – 110 092. (Pan : Bbfps2668B) (Appellant) (Respondent) Assessee By : Shri Sumit Lal Chandani, Advocate Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 19.01.2025 Date Of Order : 28.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 03.03.2025 For The Assessment Year 2013-14 Raising Following Grounds Of Appeal :- 1. That The Notice Issued Under Section 148 Of The Income Tax Act, 1961 (‘The Act’) & The Consequential Proceedings Are Illegal, Bad In Law, Without Jurisdiction & Barred By Time Limitation. 2. That The Commissioner Of Income Tax (Appeals) [‘Cit(A)’] Has Erred In Not Quashing The Reassessment Proceedings, Which Are Ex Facie Bad In Law & In Violation Of The Settled Judicial

For Appellant: Shri Sumit Lal Chandani, AdvocateFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 115BSection 147Section 148Section 148ASection 149Section 151Section 68

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 under section 148 on or before 9-6-2022 and accordingly, impugned notice under section 148 dated

DCIT, Cr Building vs. Gulshan Polyols Limited, Laxmi Nagar

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

ITA 5551/DEL/2024[2019-20]Status: DisposedITAT Delhi28 Jan 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmadcit (Osd), Range 10, Vs. M/S. Gulshan Polyols Limited, New Delhi. G – 81, Preet Vihar, Anand Vihar, East Delhi, Delhi – 110 092. (Pan : Aabcg3954F) Co No.47/Del/2025 (In Ita No.5551/Del/2024) (Assessment Year: 2019-20) M/S. Gulshan Polyols Limited, Vs. Dcit (Osd), Range 10, G – 81, Preet Vihar, New Delhi. Anand Vihar, East Delhi, Delhi – 110 092. (Pan : Aabcg3954F) (Appellant) (Respondent) Assessee By : Mohd. Shahid, Ca Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 10.11.2025 Date Of Order : 28.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Revenue Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [“Ld. Cit (A)”, For Short] Dated 29.11.2024 For The Assessment Year

For Appellant: Mohd. Shahid, CAFor Respondent: Shri Rajesh Kumar Dhanesta, SR. DR
Section 133(6)Section 133ASection 143(2)Section 148ASection 68Section 69C

Assessee had filed its return of income declaring total income of Rs.23,69,10,390/-. The Assessing Officer observed that as per order under section 148A(d) of the Income-tax Act, 1961 (for short ‘the Act’), it was found that assessee had taken accommodation sale entry amounting to Rs.47

Jagmohan Singh Bedi, Delhi vs. Income Tax Officer, Ward 70(1), Delhi

In the result, the appeals of the assessee are partly

ITA 5069/DEL/2024[2017-18]Status: DisposedITAT Delhi28 Jan 2026AY 2017-18

Bench: Shri C.N. Prasad & Shri M. Balaganesh

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

Assessing Officer issued to assessee a notice under section 148(b) and assessee assessee replied to notice Thereafter Assessing Officer passed impugned order under section 148A(d) alleging that assessee had failed to demonstrate that certain receipts had been fully disclosed- whether since assessee had explained in reply to notice ... four lakhs and time limit for current proceedings was covered under section 149(1)(b) After approval was granted by Principal Commissioner, order under section 148A(d) was passed and reopening notice was issued on 20-4-2023 Assessee challenged impugned order and reopening notice on ground that sanction

Jagmohan Singh Bedi, Delhi vs. Income Tax Officer, Ward 70(1), Delhi

ITA 5068/DEL/2024[2016-17]Status: DisposedITAT Delhi28 Jan 2026AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh

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

Assessing Officer issued to assessee a notice under section 148(b) and assessee assessee replied to notice – Thereafter Assessing Officer passed impugned order under section 148A(d) alleging that assessee had failed to demonstrate that certain receipts had been fully disclosed- whether since assessee had explained in reply to notice ... four lakhs and time limit for current proceedings was covered under section 149(1)(b) After approval was granted by Principal Commissioner, order under section 148A(d) was passed and reopening notice was issued on 20-4-2023 Assessee challenged impugned order and reopening notice on ground that sanction

Jagmohan Singh Bedi, Delhi vs. Income Tax Officer, Ward 70(1), Delhi

ITA 5067/DEL/2024[2015-16]Status: DisposedITAT Delhi28 Jan 2026AY 2015-16

Bench: Shri C.N. Prasad & Shri M. Balaganesh

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

Assessing Officer issued to assessee a notice under section 148(b) and assessee assessee replied to notice – Thereafter Assessing Officer passed impugned order under section 148A(d) alleging that assessee had failed to demonstrate that certain receipts had been fully disclosed- whether since assessee had explained in reply to notice ... four lakhs and time limit for current proceedings was covered under section 149(1)(b) After approval was granted by Principal Commissioner, order under section 148A(d) was passed and reopening notice was issued on 20-4-2023 Assessee challenged impugned order and reopening notice on ground that sanction

Mr. Harivijay Pralhad Joshi, Pune vs. ITO Ward 3(3), Pune, Swargate

In the result, appeal of the assessee is partly allowed

ITA 2297/PUN/2025[2018-19]Status: DisposedITAT Pune27 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2297/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Mr.Harivijay Prahlad Joshi, V The Income Tax 3 & 4, Megh Terrace 55 S Officer, Rambaug, Colony, Behind Ward-3(3), Pune. Chaitanya Health Club, Kothrud, Pune – 411038. Pan: Aappj9257M Appellant/ Assessee Respondent /Revenue Assessee By Shri Piyush Bafna Revenue By Smt Neha Thakkar – (Virtual) On Rotation Duty Date Of Hearing 22/01/2026 Date Of Pronouncement 27/01/2026 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.2018-19 Dated 14.11.2024 Emanating From The Assessment Order Passed Under

Section 147Section 148Section 151Section 250Section 250(6)

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 ... Commissioner of Income Tax. 8. Hence, respectfully following the decision of Hon’ble Bombay High Court(supra) and ITAT Pune(supra), the order under Section 148A(d) of the Act, and notice under section148 are quashed. Accordingly, the legal ground raised by the assessee is allowed. Since we have decided

Thirumoorthy Revathi, Coimbatore vs. ITO, Ncw-4(4), Coimbatore

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

ITA 3188/CHNY/2025[2015-16]Status: DisposedITAT Chennai27 Jan 2026AY 2015-16

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3188/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. R. Kavitha, Addl.CIT
Section 133(6)Section 148Section 148ASection 149Section 149(1)Section 250Section 69A

hand submitted that in assessee's case the AO issued notice under section 148A(b) on 22.03.2022 and after enquiry passed the order under section 148A(d) on 31.03.2022. The ld. DR further argued that as per the 3rd proviso to section 149 of the Act for the purpose ... India, to issue a writ of certiorari to call for the records on the file of the Respondent and quash the impugned order under Section 148A(d) of the Act in PAN:ADDPL2229A dated 04.04.2022 in DIN & Notice No.ITBA/AST/F/148A/2022-23/1042464779(1) for the AY 2015~16 :- 11 -: along with the impugned

Diamond Tradecom Private Limited, Mumbai vs. Income Tax Officer Ward 12(2)(1), Mumbai

In the result, the appeal of assessee is allowed

ITA 5850/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Jan 2026AY 2016-17

Bench: Shri Pawan Singh(Physical Hearing) Diamond Tradecom Private Limited Ito,Ward-12(2)(1), Mumbai Shop No. 1, Shiv Ganga Chs Ltd., Vs Room No. 147B, Aayakar Bhavan, Ram Kuwar Thakur Road, M.K. Road, Dahisar (East), Mumbai – 400020. Mumbai – 400068. [Pan No. Aaccd8131A] Appellant / Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 149(1)(a)Section 151Section 250Section 250(6)Section 254(1)Section 69A

record that after decision of Hon’ble Apex Court in UOI vs Ashish Agarwal (supra), the assessee was allowed fresh opportunity and order under section 148A(d) was passed on 30.07.2022. A fresh notice under section 148 dated 30.07.200 was issued with the prior approval

Deupty Commissioner of Income Tax, Mumbai vs. Anand Rathi Commodities Limited, Mumbai

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

ITA 5983/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jan 2026AY 2018-19

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar

Section 143(3)Section 147Section 148Section 148ASection 250Section 270ASection 36(1)(vii)Section 37(1)

wherein the returned loss was accepted without making any addition. 3. Subsequently, proceedings for reopening of the assessment were initiated. An order under section 148A(d) of the Act dated 27.03.2024 was passed after obtaining approval from the competent authority, followed by issuance of notice under section

Inderjyot Singh, New Delhi vs. ITO Ward 44(1), Delhi

Appeal is allowed in above terms

ITA 8758/DEL/2025[2017-18]Status: DisposedITAT Delhi22 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 8758/Del/2025 : Asstt. Year: 2017-18 Inderjyot Singh, Vs Income Tax Officer, 6/2, Dlf Indl. Area, Moti Nagar, Ward-44(1), New Delhi-110015 New Delhi-110002 (Appellant) (Respondent) Pan No. Abyps9796E Assessee By: Sh. Rajesh Dureja, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 22.01.2026 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, New Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082168393(1) Dated 30.10.2025, In Proceedings U/S 147 R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rajesh Dureja, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 148Section 148ASection 149(1)Section 151

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

Badariprasad, Guna vs. Income Tax Officer Guna, Guna

In the result, appeal filed by the assessee is allowed

ITA 473/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshbadriprasad, Vs. Income Tax Officer, Heerabagh Colony, Guna, Guna, Gwalior Gwalior (Appellant) (Respondent) Pan: Arapr6314B

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Badriprasad 3. I have heard the rival contentions and perused the materials available on record. It is not in dispute that the order under section 148A(d) of the Income Tax Act, 1961 (in short 'Act') dated 27.03.2022 was passed by the JAO. It is also not in dispute that ... eyes of law. 3. Ground No.5 is reproduced as under: 5. The NFAC, Delhi failed to appreciate that the passing of the order under Section 148A(d) of the Act by the JAO was in complete defiance to theprescription of law/ procedure in relation there toand hence ought to have

Haricharan Rathore, Ashok Nagar vs. Income Tax Officer, Ashok Nagar

In the result, appeal filed by the assessee is allowed

ITA 472/AGR/2025[2020-21]Status: DisposedITAT Agra21 Jan 2026AY 2020-21

Bench: Shri M. Balaganeshharicharan Rathore, Vs. Ito, 125, Path Kheda, Ashok Ashok Nagar, Nagar, Mp Mp (Appellant) (Respondent) Pan: Csqpr0999M Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

Rathore 3. I have heard the rival contentions and perused the materials available on record. It is not in dispute that the order under section 148A(d) of the Income Tax Act, 1961 (in short 'Act') dated 22.03.2024 was passed by the JAO. It is also not in dispute that ... eyes of law. 3. Ground No.5 is reproduced as under: 5. The NFAC, Delhi failed to appreciate that the passing of the order under Section 148A(d) of the Act by the JAO was in complete defiance to theprescription of law/ procedure in relation there toand hence ought to have

Ashok Sahu, Jhansi vs. Income Tax Officer, Ward 2(3)(1), Jhansi

In the result, appeal filed by the assessee is allowed

ITA 452/AGR/2025[2018-19]Status: DisposedITAT Agra21 Jan 2026AY 2018-19

Bench: Shri M. Balaganeshashok Sahu, Vs. Income Tax Officer, Purana Bazar, Chirgaon, Ward-2(3)(1), Jhansi Jhansi (Appellant) (Respondent) Pan: Jgsps3446H Sunita, Vs. Assessment Unit, Ward No. 2, Chobyana Income Tax Talrehat Lake View Department, Camp, Lalitpur, Lalitpur, National Faceless Up Appeal Centre, Delhi (Appellant) (Respondent) Pan: Jgps3438H

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 144BSection 147Section 148Section 148ASection 151Section 151A

first. 4. I have heard the rival contentions and perused the materials available on record. It is not in dispute that the order under section 148A(d) of the Income Tax Act, 1961 (in short 'Act') dated 31.03.2022 was passed by the JAO. It is also not in dispute that ... Ground No.5 is reproduced as under: ITA No. 432/AGR/2025 5. The NFAC, Delhi failed to appreciate that the passing of the order under Section 148A(d) of the Act by the JAO was in complete defiance to theprescription of law/ procedure in relation there toand hence ought to have appreciated