“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)

Dy. Commissioner of Income-Tax-1(1)(1), Mumbai vs. M/S. Hindustan Petroleum Corporation Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3866/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Feb 2026AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawaldy. Commissioner Of Income- Vs Hindustan Petroleum Tax-1(1)(1), Corporation Limited Mumbai Petroleum House Jamshedji Tata Road, Marine Lines S.O Mumbai - 400020 (Pan: Aaach1118B) Appellant Respondent Present For: Assessee By : Ms. Hirali Desai, Ca Revenue By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 23.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1075143492(1) Dated 27.03.2025 Passed Against The Assessment Order By The Assessment Unit, U/S. 147 R.W.S. 144 Read With Sec. 144B Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 25.05.2023 For Ay 2015-16. 2. Grounds Taken By The Revenue Are Reproduced As Under: “. Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Erred In Deleting The Addition Of Rs. 9,60,00,000/ - On Account Of Disallowance Of Investment Allowance Claimed U/S. 32Ac On Dispensing Units In Retail Outlets Ignoring The Fact That The Dispensing Units Do Not Fall Within The Meaning Of Plant & Hence, Not Eligible For Claim Of Deduction U/S. 32Ac.

For Appellant: Ms. Hirali Desai, CAFor Respondent: Shri Ritesh Misra, CIT DR

Section 115JSection 144BSection 147Section 148Section 151ASection 32A

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

Sudha Doshi, Hyderabad vs. ITO - Ward 5(1), Hyderabad

ITA 1775/HYD/2025[2015-16]Status: DisposedITAT Hyderabad25 Feb 2026AY 2015-16

For Appellant: Shri S. VenkateshwarluFor Respondent: Shri K. Vamsi Krishna

Section 143(1)Section 143(3)Section 147Section 148Section 148ASection 151ASection 250(6)

they stood immediately before the commencement of the Finance Act, 2021. We say so, for the reason that as per the pre-amended section 149(1)(b) of the Act a notice under section 148 of the Act for the AY 2015-16 could have been issued

Jadagadder Pakkerappa, Legal Heir Sarojamma, Shikaripura vs. Income Tax Officer, Ward-1 & Tps, Shimoga

In the result, appeal filed by the assessee is allowed

ITA 1406/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Feb 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17

For Appellant: Sri Varun Bhat, A.RFor Respondent: Sri Balusamy N., D.R

Section 142(1)Section 144Section 147Section 148Section 15Section 250

first instance. It ought to be noted that the period allowable for initiating the proceedings under section 148 is the period prescribed under section 149(1)(b) which position is not in dispute and accordingly, proceedings ought to have been initiated as on 31-3-2018. 15. The question ... under section 148 is the issuance of notice, which notice to be valid is required to be initiated within the time prescribed under section 149(1)(b). Notice issued against Kurkal Gopal Shetty on 28-3-2018 being against a dead person, at the very inception would

Ramesh Amratlal Brahmbhatt, Mumbai vs. ITO Ward 34(3)(2), Mumbai

In the result, the reassessment order dated 20

ITA 9067/MUM/2025[2014-15]Status: DisposedITAT Mumbai25 Feb 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarramesh Amratlal Ito Ward 34(3)(2), Brahmbhatt Kautilya Bhavan, 43 Rajnigandha, Vs. Bandra Kurla Gulmohar Cross Road No. Complex, Mumbai – 11, J V P D Scheme, 400 051 Juhu, Mumbai-400 049 Pan/Gir No. Aabpb7235R (Applicant) (Respondent) Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 23.02.2026 Date Of Pronouncement 25.02.2026

Section 10(38)Section 144BSection 147Section 148Section 149Section 151ASection 68

Departmental Representative supported the orders of the lower authorities. It was submitted that the escaped income exceeded Rs. 50,00,000/- and therefore section 149(1)(b) applies providing extended limitation of ten years. 10. Reliance was placed on the judgment of the Hon’ble Madras High Court in Kandasamy ... ACIT (supra)in support of the contention that the notice issued under section 148 dated 29.07.2022 is within limitation in view of section 149(1)(b) of the Act. 16. We have carefully considered the said decision and find that the reliance placed by the Revenue is misplaced

Hotel Selection Grand, Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

ITA 741/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2016-17

Bench: Shri Ravish Sood, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपीलसं./I.T.A.No.741/Viz/2025 (निर्धारण वर्ष / Assessment Year:2016-17) Hotel Selection Grand Gollagundam Centre K.N. Road Tadepalligudem-534101 Andhra Pradesh [Pan: Aakfh0778C] Vs. Income Tax Officer, Ward -1 Aayakar Bhavan, 2-1-56/1 Opp. Punjab National Bank K.N.Road, Tadepalligudem – 534101 Andhra Pradesh करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement Per Ravish Sood, Jm: : Shri I. Kama Sastry, Ca : Sri K.Prasad, Sr.Dr : 12.02.2026 : 18.02.2026 आदेश /Order The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 24.10.2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short "A.O”) Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (For Short, "The Act"), Dated 06.01.2025 For The Assessment Year 2016-17. The Assessee Firm Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us: "1. The Notice Under Section 148 Issued On 18.04.20232 For The

Section 115BSection 142ASection 147Section 148Section 148ASection 149(1)(b)Section 151ASection 234ASection 69A

notice under section 148 issued on 18.04.20232 for the assessment year 2065-17 is barred by limitation as per the first proviso to section 149(1)(b) (new section inserted by the Finance Act, 2021, w.e.f 01.04.2021} being beyond six years from the end of the assessment year ... provisions section 149(1)(b) existing upto 31.03.2021. 2. The notice issued under section 148 dated 18.04.2023 is invalid as it has given only 30 days-time from the date of service of the notice for filing response thereto as against the period of three months from

Andhra Pradesh Housing Board, Vijayawada vs. ACIT/DCIT, Circle-1(1), Vijayawada

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

ITA 732/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam18 Feb 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 143(2)Section 147Section 148Section 148ASection 250

they stood immediately before the commencement of the Finance Act, 2021. We say so, for the reason that as per the pre-amended section 149(1)(b) of the Act, a notice under section 148 of the Act for the AY 2015-16 could have been issued ... amended Section 149(1) of the Act. The relevant paragraphs 49 and 53 thereof are extracted hereunder: “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 for the assessment

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

In the result, appeal filed by the assessee is allowed

ITA 1894/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita No.1894/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2014-15) M/S. Exel Rubber (P) Ltd Vs. Dy.Cit Hyderabad Central Circle 1(2) Pan:Aaace4495J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Narendra Kumar Naik, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 20/01/2026 घोषणा की तारीख/Pronouncement: 18/02/2026 आदेश/Order Per Manjunatha, G. A.M. This Appeal Is Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-11 Hyderabad, Dated 11/10/2025 For The A.Y 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Narendra Kumar Naik, CIT (DR)

Section 132Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 69A

Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next ... finding at the time of granting the sanction as to why the reopening beyond 3 years is in accordance with the provisions of section 149(1)(b) of the Act. The alleged material which is the basis of reopening of the assessment does not reveal the fact that the income

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1874/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.1870 To 1875/Hyd/2025 Assessment Years 2014-2015 To 2019-2020 Vilas Polymer Private The Dcit, Limited, Hyderabad. Central Circle-1(2), Vs. Pin – 500 090 Hyderabad – 500 004. Pan Aaacv9854A Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit- Dr सुनवाई की तारीख/Date Of Hearing: 19.01.2026 घोषणा की तारीख/Pronouncement: 18.02.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad.

In the result, all the six appeals i

ITA 1873/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(tii). Accordingly grant of sanction is liable to be declared as nullity and invalid and _ resultantly, impugned ... Explanation (2) to section 148 of the I.T. Act as well as approval from the DGIT for complying the conditions laid down in section 149(1)(b) r.w.s. 151 of the I.T. Act because the notice u/s 148 of the Act was issued beyond 3 years. 10. The next

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1872/HYD/2025[2016-17]Status: DisposedITAT Hyderabad18 Feb 2026AY 2016-17

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

Vilas Polymer Private Limited, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, all the six appeals i

ITA 1870/HYD/2025[2014-15]Status: DisposedITAT Hyderabad18 Feb 2026AY 2014-15

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-

Section 132Section 143(3)Section 148Section 149Section 149(1)(b)Section 151

Kamalapat Ratanchand Chopra, Mumbai vs. Dy. Commissioner of Income Tax, Circle-19(1), Mumbai

ITA 7880/MUM/2025[2013-14]Status: DisposedITAT Mumbai18 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawal

Section 10(38)Section 143(3)Section 147Section 148Section 148ASection 149(1)Section 151ASection 69C

relevant assessment year i.e., AY 2013-14. According to the assessee, it is contrary to the mandate of the first proviso below section 149(1)(b) and therefore is invalid, bad in law and leading the impugned assessment proceedings as well as the impugned assessment order bad in law liable ... retrospective operation to protect the interest of assessees. In the present case for A.Y. 2014-15, under the old regime as per section 149(1)(b), no notice u/s 148 could have been issued beyond 31.03.2021, considering limitation of six years. TOLA read with the Act, extended the time

Rakhi Mondal, Birbhum vs. Assessment Unit, Income Tax Department, New Delhi

In the result, appeal of the assessee is allowed

ITA 2151/KOL/2025[2017-2018]Status: DisposedITAT Kolkata17 Feb 2026AY 2017-2018

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 148Section 148ASection 149Section 149(1)Section 149(1)(b)Section 250Section 69A

order of Ld. CIT(A) upholding the assessment which has been invalidly reopened and is not in accordance with the provision of section 149(1)(b) of the Act. 3. The facts in brief are that the assessee has not filed return of income for the assessment year ... admittedly the case was opened beyond a period of three years from the end of relevant assessment year and therefore, in terms of section 149(1)(b) of the Act there are certain conditions which are to be fulfilled before issuance of any notice

Anju Purohit, Thane vs. ITO Ward-3(1), Kalyan

In the result appeal for assessment year 2017-18 stands allowed on legal issue raised in additional ground vide application dated 07/01/2026 and appeal for assessment year

ITA 6345/MUM/2025[2018-19]Status: DisposedITAT Mumbai17 Feb 2026AY 2018-19

Bench: Smt. Beena Pillai ()

Section 131Section 148Section 69A

observation of Hon’ble Supreme court on this aspect are reproduced as under: “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 for the assessment year ... 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 P a g e | 7 ITA No. 6344& 6345/Mum/2025 Anju Purohit year

Anju Purohit, Mumbai vs. ITO Ward-3(1), Kalyan

In the result appeal for assessment year 2017-18 stands allowed on legal issue raised in additional ground vide application dated 07/01/2026 and appeal for assessment year

ITA 6344/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 131Section 148Section 69A

Ashok Kumar, Merrut vs. ITO, Meeut

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

ITA 5090/DEL/2025[2011-12]Status: DisposedITAT Delhi17 Feb 2026AY 2011-12

Bench: Shri C.N. Prasadassessment Year 2011-12 Asok Kumar S/O Sher Singh Vs. Ito 24, Nagli, Azamabad Ward -1 (1) Meerut -250001 Meerut Pan No.Blapk3060J Appellant Respondent Appellant Sh. Manish Kumar, Advocate Respondent Sh. Manoj Kumar, Sr. Dr

Section 142Section 148

impugned assessment order the alleged figure of escapement is more than 1 lac and, therefore, as per the provisions of section 149(1)(b) of the Act the foundational u/s.148 of the Act was liable to be issued within the maximum period of six years from

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

they stood immediately before the commencement of the Finance Act, 2021. I say so, for the reason that as per the pre-amended section 149(1)(b) of the Act, a notice under section 148 of the Act for the AY 2015-16 could have been issued ... amended Section 149(1) of the Act. The relevant paragraphs 49 and 53 thereof are extracted hereunder: “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 for the assessment

Saikat Chinmay Bhattacharya, Mumbai vs. Dy. CIT, International Taxation, Circle 1(1), Bangalore

ITA 582/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.582/Bang/2025

For Appellant: CA Darshit Naik, A.RFor Respondent: Dr. Divya K.J, CIT D.R

Section 147Section 148Section 69

08/04/2022. It is also an undisputed fact that the last date for issuing the notice u/s 148 of the Act under erstwhile section 149(1)(b) of the for the AY 2015-16 was 31/03/2022 (6 years from the end of the assessment year). Now, it is apposite here ... better appreciation of fact which are detailed below- Particulars Date Paper Book reference NA Last date for issuing notice u/s. 148 under erstwhile section 149(1)(b) for AY 2015-16 (6 years from end of AY) 31/03/2022 Issuance of Show cause notice u/s. 148A(b) 25/03/2022 Due Date/time provided

Arun Duraiswamy, Mysore, Karnataka vs. ITO, Intl. Taxation Ward 1(1), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 193/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Deepak Gunashekar, A.RFor Respondent: Dr. Divya K.J, CIT D.R

Section 139Section 147Section 148Section 148ASection 149Section 69Section 69C

29/04/2022. It is also an undisputed fact that the last date for issuing the notice u/s 148 of the Act under erstwhile section 149(1)(b) of the for the AY 2015-16 was 31/03/2022 (6 years from the end of the assessment year). Now, it is apposite here ... appreciation of fact which are detailed below- Particulars Date Paper Book Ref. Last date for issuing notice u/s. 31/03/2022 NA 148 under erstwhile section 149(1)(b) for AY 2015-16 (6 years from end of AY) Issuance of Show cause notice 26/03/2022 15 u/s. 148A(b) Due Date/time provided

Kantilal Ranchhodbhai Nakum, Jamnagar vs. ITO Ward - 1(3), Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 551/RJT/2025[2015-16]Status: DisposedITAT Rajkot13 Feb 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.551/Rjt/2025 Assessment Year: 2015-16 Kantilal Ranchhodbhai Nakum Income Tax Officer, Ward-1(3), Plot No.762, Gidc, Phase-2, बनाम/ Jamnagar, Aaykar Bhawan, Nr. Dared, Jamnagar-361 004 Vs. Chamber Of Commerce Hall, Jamnagar- Rajkot Highway, Jamnagar-361 001 "ायीलेखासं/.जीआइआरसं./ Pan/Gir No.: Aflpn 8072 P (अपीलाथ"/Appellant) (""थ"/Respondent) : िनधा"रती की ओर से/Assessee By : Shri Ravindra Manek, Ar राज" की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख/Date Of Pronouncement : 13/02/2026 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2015-16, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals) [In Short, “Cit(A)”] Dated 29.07.2025, Which In Turn Arises Out Of An Assessment Order Passed By Assessing Officer U/S 147 R.W.S. 144B Of The Act, On 12.05.2023. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1.The Hon’Ble Cit(A) Erred In Law & On Facts In Confirming Reopening Of Assessment U/S 148 Of The Act.

For Appellant: Shri Ravindra Manek, ARFor Respondent: Shri Sanjay Punglia, CIT-DR

Section 144BSection 147Section 148Section 148ASection 234ASection 250Section 271(1)(c)

b) is time barred. That is, the time limit of 6 years from the end of assessment year 2015-16, bearing in mind Section 149(1)(b) of the Act, as it existed prior to 4 Kantilal R Nakum 01.04.2021, then notice u/s 148A(b) would be time barred ... 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