“Section 149(1)(b)”

Section References (mined)Section 149Section 149(1)(b)664 judgments

The decision most relied on for Section 149(1)(b) is Union of India v. Ashish Agarwal (444 ITR 1), cited in 524 judgments on BharatTax.

Leading authorities on Section 149(1)(b)

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.

535 (Del); 6. Tata Teleservices v. UOI

385 ITR 497 · 2016 · High Court

163

citing judgments

Orders passed under section 201(1) are barred by limitation if the prescribed period of limitation under section 201(3) had expired before the amendment by the Finance Act, 2014 came into force. The amended section 201(3) does not apply retrospectively.

7.14 In CIT v. Gwalior Rayon Silk Mfg. Co. Ltd.

196 ITR 149 · 1992 · Supreme Court

120

citing judgments

Incentive provisions in the Income-tax Act, particularly those granting deductions for new industrial undertakings, must be construed liberally to achieve their legislative purpose. This principle guides the interpretation of conditions such as what constitutes a 'new undertaking' versus a 'splitting up or reconstruction' of an existing business for claiming deductions.

Deepak Steel and Power Ltd. v. Central Board of Direct Taxes

174 Taxmann.com 144 · 2025 · Supreme Court

citing judgments

Reassessment notices issued after April 1, 2021, for Assessment Year 2015-16 are time-barred. The relaxation provided by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, does not extend the period of limitation for such notices.

Ravi Badalia v. DCIT

158 Taxmann.com 373 · Reported

citing judgments

Additions made in respect of credits reflected in foreign bank accounts for unabated assessment years must be based on incriminating material found during the search.

M B Traders v. ACIT

132 TTJ 490 · 2010 · ITAT

citing judgments

Section 148 notices can be issued at any time for assessments or reassessments made in consequence of or to give effect to any final finding, direction, or order of any higher authority.

B.K Gooyee v. CIT

62 ITR 109 · 1966 · High Court

citing judgments

A notice issued under section 34 of the Income-tax Act, 1922, that is not signed by the Income Tax Officer is invalid and considered no notice at all, as the signature is an essential and integral part of the notice.

P. Satyanarayana Chetty v. Income Tax Officer

101 ITR 385 · 1975 · High Court

citing judgments

Sanction for reassessment proceedings under Section 151 of the Income Tax Act must be granted with due application of mind and cannot be a mechanical or routine exercise.

Judgments citing Section 149(1)(b)

Balbir Singh, Delhi vs. AO, National Faceless Assessment Centre, Delhi

In the result, Appeal of the Assessee in ITA Nos

ITA 5761/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Jul 2025AY 2015-16

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.I.T.A. No. 5755/Del/2024 (A.Y 2013-14) I.T.A. No. 5756/Del/2024 (A.Y 2014-15) I.T.A. No. 5761/Del/2024 (A.Y 2015-16)

Section 148Section 148oSection 149Section 149(1)

such notice could not have been issued at that time on account of being beyond the time limit specified under the provisions of section 149(1)(b), as it stood immediately before the commencement of the Finance Act, 2021. 15. Section 149 of the Act, prior to its amendment

Income Tax Officer-3(1), Raipur vs. Vighneshwar Ispat Pvt Ltd, Raipur

In the result, appeal of the revenue is dismissed

ITA 343/RPR/2025[2014-15]Status: DisposedITAT Raipur30 Jul 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.343/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Income Tax Officer-3(1), Raipur (C.G.)

For Appellant: Shri Rajesh Kumar Chawda &For Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 148Section 148ASection 149(1)(b)Section 68

have escaped assessment exceeded Rs. 50 lakh and was represented in the form of asset thereby falling squarely within the scope of Section 149(1)(b)?" 4. "Whether on the facts and in the circumstances of the case, the Id. CIT(A) was justified in deleting the addition of Rs.2

Kush Trading & Commerce Pvt. Ltd., New Barrackpur vs. ITO, Ward 4(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1015/KOL/2025[2014-2015]Status: DisposedITAT Kolkata30 Jul 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Kush Trading & Commerce Pvt. Income Tax Officer, Ward 4(4) Ltd. Aayakar Bhavan, P-7 125/1, Haren Mukherjee Road, Chowringhee Square, Vs. New Barrackpur, North 24 Pgs. Kolkata-700069, Pin-700131, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabck2078G Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Sandip Sarkard, Dr Date Of Hearing: 16.07.2025 Date Of Pronouncement: 30.07.2025

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Sandip Sarkard, DR

Section 147Section 148Section 148A

observed and held as under: - “25. Thus, the first and foremost question to be addressed is whether the conditions as specified under Section 149(1)(b) of the Act are satisfied. As is apparent from the plain language of the said clause that, essentially, three conditions are required

Heena Irfan Bepari, Sangli vs. Income Tax Officer, Sangli

In the result, appeal of the assessee is partly allowed

ITA 1185/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jul 2025AY 2015-16

Section 148Section 148ASection 149Section 250Section 44A

applies to the entire Income-tax Act, including sections 149 and 151 of the new regime. Once the first proviso to section 149(1)(b) is read with Taxation and other Laws (Relxation and Amendment of Certain Provisions) Act, 2020, then all the notices issued between April 1

Nimmagadda Muralidhar, Nidadavole vs. The Income-Tax Officer, Ward - 1, Tanuku

In the result, appeal filed by the assessee is allowed

ITA 188/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.188/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Vs. Income Tax Officer-Ward – 1 Nimmagadda Muralidhar D.No. 3-123 Income Tax Office Samisragudem Village Aayakar Bhavan Near Zph High School Sajjapuram, Tanuku – 534211 Nidadavole Mandal Andhra Pradesh West Godavari District Andhra Pradesh [Pan:Anbpn7016M] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Gvn Hari, Advocate करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr. Ar

Section 139Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 69A

notice under section 148 of the Act was issued on 06.04.2022 for the A.Y.2015-16 wherein the limitation expires on 31.03.2022 as per section 149(1)(b) of the unamended provisions. On this issue, Ld.AR placed heavy reliance on the decision of the Co-ordinate Bench in the case of Babu ... contention of the assessee that the said notice is barred by limitation as per the first proviso of the unamended proviso to section 149(1)(b) of the Act which has been confirmed by the Hon’ble Supreme Court in the case of UOI v. Rajeev Page. No 5 I.T.A.No

M/S Om Shriniwas Developers, Pune vs. ITO Wared-6(3), Pune

In the result, appeal of the assessee is partly allowed

ITA 1345/PUN/2025[2016-17]Status: DisposedITAT Pune24 Jul 2025AY 2016-17

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.1345/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 M/S.Om Shriniwas Developers, V The Income Tax Officer, Off No.2 & 3, Vastusadan S Ward-6(3), Pune. Bldg, 743, Guruwar Peth, Pune – 411042. Maharashtra. Pan: Aabfo7491G Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Smt. N C Shilpa – Addl.Cit(Dr) Date Of Hearing 01/07/2025 Date Of Pronouncement 24/07/2025

Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 250Section 43C

scheme of the Income-tax Act, 1961 ('the Act') it be held that the case so re- opened is against the provisions of section 149(1)(b) of the Act since the income alleged to have been escaped from assessment is below Rs.50,00,000/-. Accordingly, the assessment proceedings

Pramod Lakra Deputy Commissioner of Income Tax, Circle-11(1), Kolkata vs. Urvashi Sarees Pvt. Ltd, Kolkata

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

ITA 222/KOL/2025[2015-16]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-16

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

conceded on behalf of the Revenue that all notices issued under the new regime by invoking the six year time limit prescribed under section 149(1)(b) of the old regime will have to be dropped if the income chargeable to tax which has escaped assessment is less than Rupees

Urvashi Sarees Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

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

ITA 1946/KOL/2024[2015-2016]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-2016

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

Deepak Agarwal, Delhi vs. DCIT, Central Circle-25, Delhi

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

ITA 2307/DEL/2025[2015-16]Status: DisposedITAT Delhi23 Jul 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2307/Del/2025 िनधा"रणवष"/Assessment Year:2015-16 बनाम Sh. Deepak Agarwal Dcit, B-260, 3Rd Floor, Yozna Vihar, Vs. Central Circle-25, Delhi. Delhi. Pan No.Adkpa0795K अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 148ASection 149(1)Section 149(1)(b)Section 151Section 250Section 68

ITA No.2307/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A” NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER

Amrita Jhunjhunwala, L/H of Saket Khaitan (Since Deceased), Kolkata vs. ACIT, Central Circle 3(4), Kolkata

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

ITA 186/KOL/2025[2019-20]Status: DisposedITAT Kolkata22 Jul 2025AY 2019-20

Bench: the Ld. CIT(A) wherein the appeal was disposed off on the ground that appeal has been filed against the order passed u/s 154 of the Act though the grounds of appeal has been taken against the order passed u/s 143(3) of the act.

Section 142Section 143Section 143(2)Section 143(3)Section 148Section 149(1)(b)Section 154Section 159Section 159(2)(b)

deceased's-legal representatives are permissible only if initiated in compliance with section 159(2)(b) - Held, yes - Whether since time limit under section 149(1)(b) for initiating proceedings for assessment year 2016-17 had expired, proceedings under section 148 could not have been initiated against legal representative

Solo Hotels India Private Limited, Kolkata vs. Circle 11(1).Kolkata, Kolkata

In the result, appeal filed by the Revenue is dismissed as infructuous and Cross

ITA 2540/KOL/2024[2015-16]Status: DisposedITAT Kolkata22 Jul 2025AY 2015-16

Bench: The Ld. Cit(A), Wherein Appeal Of The Assessee Has Been Dismissed As There Was Non-Compliance On Behalf Of The Assessee. Being Aggrieved By & Dissatisfied The Assessee Preferred Appeal Before Us.

Section 142(1)Section 147Section 148Section 148ASection 149Section 250

TOLA applies to the entire Income-tax Act, including Sections 149 and 151 of the new regime. Once the first proviso to Section 149(1)(b) is read with TOLA, then all the notices issued between 1 April 2021 and 30 June 2021 pertaining to assessment years ... applies to the entire Income-tax Act, including sections 149 and 151 of the new regime. Once the first proviso to section 149(1)(b) is read with Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, then all the notices issued between April 1

Mrs. Snehal Sameer Bhujbal, Pune vs. ITO, Ward 13(2), Pune

Accordingly, Ground No.1 of the Assessee is allowed

ITA 1549/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jul 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1549/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Mrs. Snehal Sameer Bhujbal, V The Income Tax Officer, Sanswadi, Nagar Road, S Ward-13(2), Pune. Pune – 412208. Maharashtra. Pan: Blcpb5495C Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 17/07/2025 Date Of Pronouncement 21/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By 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 16.05.2025, Emanating From Order U/S.147 R.W.S 144 Of The Income Tax Act, 1961, Dated 19.01.2024. The Assessee Has Raised Following Grounds Of Appeal : “1. On The Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 ('The Act') It Be Held

Section 147Section 148ASection 149(1)(b)Section 151Section 250

Anil Singh, Kolkata vs. I.T.O., Ward - 49(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 531/KOL/2025[2017-2018]Status: DisposedITAT Kolkata16 Jul 2025AY 2017-2018

Bench: Shri George Mathanआयकर अपील सं/Ita No.531/Kol/2025 (नििाारण वर्ा / Assessment Year :2017-2018) Anil Singh Vs Ito Ward-49(1), Kolkata/Nfac 4, Railway Gate, Lalkuthi, Kamarhati, Kolkata Pan No. : Bflps 0954 J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Soumitra Choudhury, Advocate राजस्व की ओर से /Revenue By : Smt. Sima Das Biswas, Jcit-Sr.Dr सुनवाई की तारीख / Date Of Hearing : 16/07/2025 घोषणा की तारीख/Date Of Pronouncement : 16/07/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 29.07.2024 For The Assessment Year 2017-2018. 2. Shri Soumitra Choudhury, Ld.Ar Appeared On Behalf Of The Assessee & Smt. Sima Das Biswas, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. The Appeal Of The Assessee Is Barred By 168 Days. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Stating Therein Sufficient Reasons For Delay, Which Are Plausible & Not Found To Be False. Ld. Sr.Dr Also Did Not Raise Any Serious Objection To Condone The Delay. Accordingly, Delay Of 168 Days In Filing The Present Appeal By The Assessee Is Condoned & The Appeal Is Admitted For Hearing. 4. It Was Submitted By The Ld. Ar That This Is A Case Of Reopening & Issuance Of Notice U/S.148 Of The Act. It Was The Submission That The Notice

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Smt. Sima Das Biswas, JCIT-Sr.DR

Section 148Section 148ASection 151

under the new regime will be applicable. The three year time limit will expire on 31 March 2022. 49. The first proviso to Section 149(1)(b) requires the determination of whether the time limit prescribed under Section 149(1)(b) of the old regime continues to exist ... period would have expired on 31 March 2023, while the six year period 8 expired on 31 March 2019. Without the proviso to Section 149(1)(b) of the new regime, the Revenue could have had the power to reopen assessments for the year 2012-2013 if the escaped assessment

Etc Electric Private Limited, Kolkata vs. ITO, Ward 5(1), Kolkata

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

ITA 342/KOL/2025[2018-19]Status: DisposedITAT Kolkata15 Jul 2025AY 2018-19

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

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

under the new regime will be applicable. The three year time limit will expire on 31 March 2022. 49. The first proviso to Section 149(1)(b) requires the determination of whether the time limit prescribed under Section 149(1)(b) of the old regime continues to exist ... expired at the time of issuance of the notice. This also ensures that the new time limit of ten years prescribed under Section 149(1)(b) of the new regime applies prospectively. For example, for the assessment year 2012-2013, the ten year period would have expired on 31 March

Vaka Ghanta Nageswararao, Guntur vs. Income Tax Officer, Ward - 1, Tenali

In the result, appeal filed by the assessee is allowed

ITA 251/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam10 Jul 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.251/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Vs. Income Tax Officer-Ward – 1 Vaka Ghanta Nageswararao 4-82-A, Gullapalli Tenali -522201 Goudapalem, Cherukapalli Mandal Andhra Pradesh Guntur – 522309 Andhra Pradesh [Pan:Afjpn4315H] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Malladi Muralidhar, Ca करदाता का प्रतततितित्व/ Assessee Represented By राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr. Ar

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 149(1)(b)Section 250(6)Section 69ASection 80C

raised by the assessee challenging the issuance of notice under section 148 of the Act considering the amendment to provisions of section 149(1)(b) of the Act. 4. On being aggrieved by the order of the Ld. CIT(A), assessee is in appeal before us by raising following grounds ... notice under section 148 of the Act was issued on 07.04.2022 for the A.Y.2015-16 wherein the limitation expires on 31.03.2022 as per section 149(1)(b) of the unamended provisions. On this issue, Ld.AR placed heavy reliance on the decision of the Co-ordinate Bench in the case of Mukaesh

Murali Mohan Reddy Bonthu, Vijayawada vs. Income-Tax Officer, Ward-3(1), Vijayawada

In the result, appeal of the assessee is allowed

ITA 265/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam04 Jul 2025AY 2013-14

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.265/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2013-14) Murali Mohan Reddy Bonthu V. Income Tax Officer – Ward – 3(1) 14/4, Flat No. 503 Cr Building, 1St Floor Annex Sree Satya Sai Towers M.G. Road, Vijayawada – 522002 Andhra Pradesh Main Road Nunna Andhra Pradesh - 521212 [Pan:Aiopb5077E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri I. Kama Sastry, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparna Villuri, Sr.Ar

Section 112Section 139(4)Section 142(1)Section 147Section 148Section 149(1)(b)Section 234ASection 54FSection 69A

above the Notice under section 148 dated 31.03.2021 issued on 15.04.2021is barred by limitation as per the first proviso to section 149(1)(b) (New) w.e.f. 01.04.2021. 3. The Assessment Unit, National Faceless Assessment Centre is not justified and the CIT(Appeals), National Faceless Appeal Centre is not justified ... that notice under section 148 of the Act dated 31.03.2021 issued on 15.04.2021 is barred by limitation as per the first proviso to section 149(1)(b) of the Act w.e.f 01.04.2021. Ld.AR pleaded that the legal ground raised by the assessee as above, shall first be addressed before adjudicating

DCIT-14(1)(1), Mumbai vs. Kalpana Madhani Securities Pvt. Ltd, Mumbai

In the result, the appeal filed by the revenue is dismissed and Cross

ITA 3846/MUM/2024[2014-2015]Status: DisposedITAT Mumbai04 Jul 2025AY 2014-2015

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhandcit-14(1)(1) M/S. Kalpana Madhani R. No. 432, 4Th Floor, Aayakar Securities Pvt. Ltd. Bhavan, M. K. Road, Vs. 11/1102, Shanti Tower, Shanti Mumbai-400 020 Path, Near Garodia Nagar, Mumbai-400 077 Pan: Aabck2968H

Section 143(3)Section 148Section 148ASection 151Section 250Section 73

basis of law which exists at the time when such a notice was issued, i.e., 28th July 2022. 22. As per the unamended Section 149(1)(b) of the Act, the outer time limit to issue a notice under Section 148 was 6 years from the end of the relevant ... under Section 148 could not have been issued at that time on account of being beyond the time limit specified under the unamended Section 149(1)(b), i.e., as it stood prior to the Finance Act, 2021. Applicability of Section 149 to be seen qua the notice under Section

Kushal Vinodkumar Bhatt Legal Heir of Late Shri Vinodkumar Ramanlal Bhatt, Anand vs. The ACIT (OSD), Ward-5, Anand

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

ITA 752/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2011-12

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 159(2)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “C” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

Bhandari Construction, Bilaspur vs. ITO Ward-1(1), Bilaspur

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

ITA 331/RPR/2025[2017-18]Status: DisposedITAT Raipur27 Jun 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.331/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Bhandari Construction Nutan Chowk, Seepat Road, Sarkanda, Bilaspur (C.G.)-495 001 Pan: Aajfb9702B .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 148Section 148ASection 151Section 69

आयकर अपील"य अ"धकरण "यायपीठ “एक-सद"य” मामला रायपुर म" IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH

Raj Bala, Haryana vs. ITO Ward-1, Narnaul

Appeal is allowed

ITA 1665/DEL/2025[2015-16]Status: DisposedITAT Delhi26 Jun 2025AY 2015-16

Bench: Sh. Satbeer Singh Godaraita No. 1665/Del/2025 : Asstt. Year : 2015-16 Raj Bala, Vs Income Tax Officer, Post Office Kanwi, Tehsil Narnaul, Ward-1, Mahendergarh, Haryana-123001 Narnaul, Haryana-123001 (Appellant) (Respondent) Pan No. Bjmpb1387H Assessee By: Sh. Parikshit Aggarwal, Ca Revenue By : Ms. Indu Bala Saini, Sr. Dr Date Of Hearing: 25.06.2025 Date Of Pronouncement: 25.06.2025 Order This Assessee’S Appeal For Assessment Year 2015-16, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1072284407(1) Dated 17.01.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Ms. Indu Bala Saini, Sr. DR

Section 147Section 148Section 149(1)(b)

assessment year 2015-16 herein since involving the alleged income escaping assessment of Rs.18,50,000/- is less than Rs.50 lacs going by section 149(1)(b) of the Act. That being the case, the tribunal finds merit in the assessee’s legal arguments that the impugned reopening