“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

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

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

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

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

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

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

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)

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1538/HYD/2025[2016-17]Status: DisposedITAT Hyderabad16 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Ys Nos. 1536 To 1539/ Sukesini Kumili, Income Tax Officer 2015-16 & Hyd/2025 Hyderabad Ward 15(1),Hyderabad 2016-17 Pan:Ckmpk5466J िनधा""रती "ारा/Assessee By: Advocate Shri S. Rama Rao राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 07/01/2016 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili (“The Assessee”) Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Advocate Shri S. Rama RaoFor Respondent: : Shri Madhukar AVES, Sr. DR

Section 144Section 147Section 148Section 148ASection 151A(1)

Sukesini Kumili 7. On perusal of above, it is evident that the order under section 148A(d) of the Act was passed by JAO on 06.04.2022. We Page 6 of 20 ITA Nos. 1536 to 1539 of 2025 Sukesini Kumili have also gone through the notice issued under section ... after 29.03.2022 shall be in accordance with the Faceless Assessment Scheme by the FAO. Hence, on perusal of the order under section 148A(d) of the Act, notice issued under section 148 of the Act and the CBDT notification, we find that in the present case, the order passed under

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1537/HYD/2025[2015-16]Status: DisposedITAT Hyderabad16 Jan 2026AY 2015-16

For Appellant: Advocate Shri S. Rama RaoFor Respondent: : Shri Madhukar AVES, Sr. DR

Section 144Section 147Section 148Section 148ASection 151A(1)

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1536/HYD/2025[2015-16]Status: DisposedITAT Hyderabad16 Jan 2026AY 2015-16

For Appellant: Advocate Shri S. Rama RaoFor Respondent: : Shri Madhukar AVES, Sr. DR

Section 144Section 147Section 148Section 148ASection 151A(1)

M/S Padma Polychem Pvt. Ltd., Delhi vs. NFAC, Assessment Unit Itd, Delhi

Appeal is allowed in above terms

ITA 5301/DEL/2025[2014-15]Status: DisposedITAT Delhi14 Jan 2026AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5301/Del/2025 : Asstt. Year : 2014-15 M/S Padma Polychem Pvt. Ltd., Vs Cit(A)/Nfac, 528/1, Karkari Road, Vishwash Delhi Nagar, Delhi-110032 (Appellant) (Respondent) Pan No. Aafcp4479A Assessee By : Sh. Rakesh Kumar, Adv. & Sh. Akshay Gupta, Ar Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 14.01.2026 Date Of Pronouncement: 14.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2014-15, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1077228877(1) Dated 19.06.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Rakesh Kumar, Adv. &For Respondent: Ms. Ankush Kalra, 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

ITO, New Delhi vs. Ruptex Mineral Water Private Limited, New Delhi

In the result, the appeal filed by the Department of Revenue is dismissed and cross-objection filed by Assessee are allowed

ITA 3073/DEL/2025[2017-18]Status: DisposedITAT Delhi14 Jan 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Income Tax Officer, Vs. Ruptex Mineral Water Private New Delhi. Limited, K No. 799/1 Village Burari Jagatpur B.O. Jagatpur New Delhi. Pin: 1100 84, Delhi Pan :Aabcr0261Q (Appellant) (Respondent)

Section 142(1)Section 144BSection 147Section 148Section 148ASection 151Section 250Section 68Section 69C

hence, notice issued u/s 148A(b) of the Act is bad in law and the same is liable to be dropped. An order under Section 148A(d) of the Act was passed on 30.07.2022, whereby the objections of the assessee was considered untenable by taking approval of Principal commissioner ... Order in the case of Ashish Agarwal notice u/s 148A(b) of the Act was issued on 18-05-2022 and consequent order under section 148A(d) of the Act on 28-07-2022 was issued. The case of the assessee relates to the A.Y. 2017-17 and the notice

Nezone Tubes Limited, Kolkata vs. DCIT, Circle 1(1), Kolkata

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

ITA 180/KOL/2025[2015-16]Status: DisposedITAT Kolkata13 Jan 2026AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 144BSection 147Section 148ASection 149(1)Section 250Section 251(1)(a)Section 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 ITA Nos.: 179 & 180/KOL/2025 AYs: 2011-12 & 2015-16 Nezone Tubes Limited. notices ought

Nezone Tubes Limited, Kolkata vs. DCIT, Circle 1(1), Kolkata

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

ITA 179/KOL/2025[2011-12]Status: DisposedITAT Kolkata13 Jan 2026AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 144BSection 147Section 148ASection 149(1)Section 250Section 251(1)(a)Section 68

Abhishek Jayketu Joshi, Mumbai vs. Ac Cir-42(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5775/MUM/2025[2019-20]Status: DisposedITAT Mumbai13 Jan 2026AY 2019-20

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarabhishek Jayketu Joshi Ac Cir-42(2)(1), C-73, Venus Society, R. G. Kautilya Bhavan, Thadani Marg, Worli Sea Vs. Mumbai-400 051 Face, Mumbai-400 018 Pan/Gir No. Ackpj8583H (Applicant) (Respondent) Assessee By Shri M. M. Golvala, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 13.01.2026

Section 132Section 132(4)Section 139(1)Section 139(5)Section 143(1)Section 144BSection 147Section 148Section 148ASection 250

furnished. 5. The Assessing Officer was not satisfied with the explanation furnished and, after obtaining approval of the specified authority, passed an order under section 148A(d), followed by issuance of notice under section 148 on 19.04.2023. In response, the assessee filed a return of income on 18.05.2023, declaring ... reproduction of Question No. 13 and the corresponding answer from the statement recorded under section 132(4), as extracted in the order under section 148A(d). It was submitted that while, on the one hand, the Assessing Officer alleged that Kisan Party of India was not engaged in any political

Harish Chandra Purohit, Ratlam vs. Income Tax Officer - 1, Ratlam

In the result- the Impugned order is set aside as and by way

ITA 221/IND/2025[2018-19]Status: DisposedITAT Indore09 Jan 2026AY 2018-19

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshiassessment Year: 2018-19

Section 142(1)Section 147Section 148Section 148ASection 250Section 253Section 69A

account vide number:-3567087907 held with “Central Bank of India” during the period relevant to the assessment year under consideration. That an order under section 148A(d) of the Act was passed by the assessing officer & a notice u/s 148 of the Act was issued to the assessee ... That the JAO has also mentioned the issue of cash deposit of Rs 20,61,55,000/- in the order under section 148A(d) of the Income Tax Act, 1961, dated 25/03/2022. The JAO(Jurisdictional Assessing Officer), has mentioned in Para 8 of the order under section 148A(d

Yadiki Pacs, Anantapur vs. Income Tax Officer, Ward-1, Anantapur

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

ITA 926/HYD/2025[AY 2019-20]Status: DisposedITAT Hyderabad09 Jan 2026

Bench: the Andhra Pradesh High Court against the Order of the Chief Commissioner of Income Tax, Hyderabad rejecting the appellant's application filed u/s 119(2)(b) of the Act to condone the delay in filing the Income Tax Return for the subject AY 2019-20 is pending for disposal as on date. 7. For that the Learned Commissioner of Income Tax (Appeals) had erred in confirming the levy of interest u/s 234A of the Act in consequence to the above." 3

Section 119(2)(b)Section 139Section 147Section 148Section 148ASection 234ASection 80ASection 80P

income, the nature and source of the said cash deposits remained unexplained. Accordingly, after following the procedure prescribed under Section 148A, an order under Section 148A(d) was passed on 28.03.2023, and thereafter, notice under Section 148 was issued to the assessee on the same date for the relevant assessment ... Jurisdictional Assessing Officer issued a show-cause notice under Section 148A(b) of the Act dated 28.02.2023, which was followed by an order under Section 148A(d) of the Act dated 28.03.2023, and thereafter issued notice under Section 148 of the Act on 28.03.2023. Since the notice under Section

Thilak Babu Boppana, Chittor vs. Income Tax Officer, Ward-1(1), Tirupati

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

ITA 1628/HYD/2025[2020-21]Status: DisposedITAT Hyderabad09 Jan 2026AY 2020-21

Bench: Shri Manjunatha G. (Accountant Member), Shri Ravish Sood (Judicial Member)

For Appellant: Shri M.M. Shabid SameerFor Respondent: Shri K. Vinoth Kannan, Sr

Section 144Section 147Section 148Section 148A

year under consideration, issued notice under section 148A(b) of the Act, dated 11/01/2024. Thereafter, the Jurisdictional Assessing Officer (JAO) passed an order under section 148A(d) of the Act, dated 24/02/2024. Notice under section 148 of the Act was issued by the JAO. However, the assessee failed to furnish ... notices under section 148 of the Act were issued by the local jurisdictional officer and not in the prescribed faceless manner. The order under section 148A(d) of the Act and the notices under section 148 of the Act are issued on 29-4- 2022, i.e., after the "Faceless Jurisdiction

Mittal Homes Pvt Ltd, Delhi vs. ITO Ward-17(1), Delhi

In the result, the appeal of the Assessee is allowed

ITA 2328/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: # Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 143(1)(a)Section 148Section 148ASection 250Section 68

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

Apcotex Industries Limited, Raogarh vs. Income Tax Officer - Circle 15(1)(1), Mumbai

In the result, having regard to the foregoing discussion and

ITA 6022/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Jan 2026AY 2013-14

Bench: Shri Amit Shuk

Section 143(3)Section 144BSection 147Section 148Section 148ASection 24Section 250Section 32

property was allegedly a deemed let-out property. On this basis, proceedings under section 148A were initiated, and after passing an order under section 148A(d) dated 28.07.2022, notice under section 148 was issued on 29.07.2022. 4. In response to the notice issued under section 148 of the Income ... Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, stood exhausted prior to the passing of the impugned order under section 148A(d) and issuance of notice under section 148. 10. The learned AR explained the chronology of events as under: i. The last date for issuance

Akshay Anand, Delhi vs. Assessing Officer, Delhi

The appeal of the assessee is allowed for statistical purposes

ITA 2273/DEL/2025[2016-17]Status: DisposedITAT Delhi08 Jan 2026AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Anmol Atrey, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 133(6)Section 144Section 147Section 148Section 148ASection 250Section 69

alleged payments as the appellant's income despite: 1. No direct evidence indicating that the appellant received the said amount. 2. The order under Section 148A(d) not mentioning that the promoters of Townhouse Café confirmed the payments were made. 3. No incriminating evidence proving that the appellant received

Deepti Social Service Society, Hindupur vs. ITO., Exemption Ward, Tirupati

ITA 920/HYD/2025[2018-19]Status: DisposedITAT Hyderabad07 Jan 2026AY 2018-19

Bench: Us:

Section 147Section 234ASection 69A

appeal, which reads as under: “1. The Ld. Jurisdictional Assessing Officer (JAO) erred in law and on facts in issuing the order under Section 148A(d) and the consequential reassessment notice under Section 148, whereas such notice is required to be issued only through the Faceless regime in accordance with ... liable to be struck down on the said count itself. Elaborating on her contention, the Ld. AR submitted that as the order under section 148A(d), dated 01/04/2022, as well as the notice under section 148 of the Act, dated 01/04/2022, had been both passed/issued by the Jurisdictional Assessing Officer

Primary Agricultural Co Op Credit Society Limited Minarpally, Minarpally Village vs. Income Tax Officer, Ward-1, Nizamabad

ITA 140/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad07 Jan 2026AY 2016-2017

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.140/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2016-17) Primary Agricultural Vs. Income Tax Officer Cooperative Credit Society Ward 1 Ltd Minarpally, Minarpally Minarpally, Nizamabad Pan:Aabap7760J (Respondent) (Appellant) निर्धारिती द्वारा / Assessee By: C.A Akshay Surana राजस्व द्वारा / Revenue By:: Smt. Helen Ruby Jesindha, Sr. Dr सुनवाई की तारीख / Date Of Hearing: 22/12/2025 घोषणा की तारीख / Pronouncement: 07/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Primary Agricultural Cooperative Credit Society Ltd Minarpally (“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 05.11.2024 For The A.Y, 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal: Page 1 Of 18

For Appellant: C.A Akshay Surana

Section 147Section 148Section 148ASection 80P

148A(d) of the Act. In this regard, the Ld. AR submitted that the notice under section 148 as well as the order under section 148A(d) of the Act were issued by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary ... scheme of faceless reassessment introduced by the CBDT. The Ld. AR invited our attention to the order under section 148A(d) of the Act, dated 22.03.2023 and the notice issued under section 148 of the Act on the same date. He demonstrated that both documents clearly bear the name

Nadeem Mohammed Iqbal Patni, Mumbai vs. ITO Ward 25(3)(1), Mumbai

ITA 5549/MUM/2025[2015-16]Status: DisposedITAT Mumbai07 Jan 2026AY 2015-16

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri M. SubramanianFor Respondent: Shri Pradipsinh Saktavat

Section 142Section 144BSection 147Section 148Section 148ASection 151

notice issued under Section 148 of the Old Regime as notice issued under Section 148A(b) of the New Regime and passed order under Section 148A(d) of the Act. Thereafter, notice under Section 148 of the New Regime was issued by the Assessing Officer Act between July and September

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, Appeal of the Assessee is allowed

ITA 5053/DEL/2025[2014-15]Status: DisposedITAT Delhi07 Jan 2026AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 144BSection 147Section 148Section 148ASection 250Section 68

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 ... beyond the period of limitation. 71. It is contended on behalf of the Revenue that the AO is required to pass an order under Section 148A(d) of the Act by the end of the month following the month on which the reply to the notice under Section 148A

ACIT Circle-28(1), New Delhi vs. Munjal Holdings, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 5834/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 250Section 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 ... 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

Income Tax Officer, Dhule vs. Santosh Jaynarayan Sharma, Dhule

In the result, the appeal filed by the Revenue is dismissed whereas the Cross Objection filed by the assessee is partly allowed

ITA 2324/PUN/2025[2017-18]Status: DisposedITAT Pune06 Jan 2026AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2324/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Sanjay DhivareFor Respondent: Shri Chinmayy Suhas

Section 133(6)Section 145(3)Section 147Section 148Section 148ASection 151Section 69

relevant Assessment Year (in the present case A.Y. 2017-18) expired on 30.06.2021, whereas Respondent No.1, despite passing order under section 148A(d) on 18.08.2022, and issuing notice under section 148 on 23.08.2022 [in respect of Assessment Year 2017-18], has obtained approval of Respondent No.2