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“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
70
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
42
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
27
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
26
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
25
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)

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, Delhi

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

ITA 2716/DEL/2025[2021-22]Status: DisposedITAT Delhi04 Feb 2026AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? Page | 3 ITA Nos.4153,4008, 2708 to 2717/Del/ 2025 Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

ITA 2715/DEL/2025[2020-21]Status: DisposedITAT Delhi04 Feb 2026AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)(b)Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? 2. Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? 5. Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

ITA 2714/DEL/2025[2019-20]Status: DisposedITAT Delhi04 Feb 2026AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? Page | 3 ITA Nos.4153,4008, 2708 to 2717/Del/ 2025 Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

ITA 2713/DEL/2025[2018-19]Status: DisposedITAT Delhi04 Feb 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? 2. Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? 5. Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

ITA 2712/DEL/2025[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)(b)Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? 2. Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? 5. Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

ITA 2711/DEL/2025[2016-17]Status: DisposedITAT Delhi04 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? 2. Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? 5. Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

ITA 2710/DEL/2025[2015-16]Status: DisposedITAT Delhi04 Feb 2026AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? Page | 3 ITA Nos.4153,4008, 2708 to 2717/Del/ 2025 Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

ITA 2709/DEL/2025[2014-15]Status: DisposedITAT Delhi04 Feb 2026AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 149(1)(b)Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? 2. Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? 5. Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

Proform Interiors Private Limited, Gurgaon vs. DCIT CC-20, New Delhi

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

ITA 2708/DEL/2025[2013-14]Status: DisposedITAT Delhi04 Feb 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

quashing the order passed as 147 r.w.s. 143(3) of the Act for AY 2012-13 by wrongly interpreting the provisions of Section 149(1)(b) and Section 153C of the Act? ITA Nos.4153,4008, 2708 to 2717/Del/2025 2. Whether on the facts and circumstances of the cate ... mean the four assessment years in addition to the preceding six AYs which are calculated from AY before the year of search ? 5. Section 149(1)(b) of the Act states no notice /s 148 of the Act can be issued if more than ten years have elapsed from

ACIT, Circle 24(1) Mumbai, Mumbai vs. Nilkamal Crates & Containers, Mumbai

ITA 3763/MUM/2025[2016-17]Status: DisposedITAT Mumbai03 Feb 2026AY 2016-17

Bench: Hon’Ble Justice (Retd.) C.V. Bhadang & Shri Arun Khodpia, Am

For Appellant: Shri Prashant Ghumare, AdvFor Respondent: C.O. No. 146/Mum/2025 in I.T.A. No. 3763/Mum/2025
Section 132Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 151Section 35(1)(i)Section 35(1)(ii)

आयकर अपीलीय अिधकरण "ाय पीठ मुंबई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE HON’BLE JUSTICE

Nalluru Constructions, Vijayawada vs. Income Tax Officer, Circle-1(1), Vijayawada

In the result, appeal of the Assessee is allowed

ITA 646/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam30 Jan 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Omkareshwar Chidaraआ.अपी.सं /Ita No.646/Viz./2025 Assessment Year 2015-2016 Nalluru Constructions, The Income Tax Officer, Vijayawada–520 010. Circle-1(1), Andhra Pradesh. Vijayawada. Vs. State Of Andhra Pradesh Pan Aaifn5778N (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri C Subrahmanyam, Ca राज" व "ारा /Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 27.01.2026 घोषणा की तारीख/Pronouncement: 30.01.2026 आदेश/Order

For Appellant: Sri C Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 250

ITAT Rules, 1963 which read as under: 1. “The notice issued u/s 148 dt. 03-04-2022 is barred by limitation as per section 149(1)(b) read with the proviso thereto, having been issued beyond the prescribed period of six years. Consequently, the reassessment order passed u/s 147 r.w.s

Vijaymala Vilas Kalokhe, Pune vs. ITO Ward-10(1), Pune

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

ITA 1666/PUN/2025[2013-14]Status: DisposedITAT Pune30 Jan 2026AY 2013-14

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1666/Pun/2025 धििाारण वर्ा / Assessment Year : 2013-14 Vijaymala Vilas Kalokhe, Ito, Ward-10(1), Pune Aditya Row House, Lane No. 2, Opp. Patel Garden, Sr. No. 8/2A, Vs. Juni Sangavi, Maharashtra-411027 Pan : Asepk8161G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Kishor B Phadke Department By : Shri Amit Bobde Date Of Hearing : 28-01-2026 Date Of 30-01-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 17.06.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2013-14. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. He Filed His Return Of Income For Ay 2013-14 Declaring Total Income Of Rs.2,21,050/-. The Case Of The Assessee Was Reopened U/S 147 Of The Income Tax Act, 1961 (The “Act”) After Following The Mandate Procedure As Laid Down Under The Relevant Provisions Of The Act. Accordingly, Statutory Notice U/S 142(1) Of The Act & Show Cause Letter(S) Were Issued To The Assessee From Time To Time. However, The Assessee Failed To File Any Response To The Said Notice(S) Which Constrained The Ld. Assessing Officer (“Ao”) To Pass An Ex-Parte Order U/S 144 Of The Act Based On The Material Available On Record. The Ld. Ao Proceeded To Complete The Assessment On Total Income Of Rs.2,66,70,989/-U/S 147 R.W.S. 144 Of The Act Thereby Making An Addition Of Rs.2,63,83,209/- On Account Of Undisclosed Long Term Capital Gain (Ltcg) By Observing As Under : “5.1. On-Going Through The Information Available On Record & In View Of The Order Passed U/S 148A(D) Of The Act Dated 21.07.2022, It Is Noticed That 2

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amit Bobde
Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 2(14)Section 2(14)(iii)Section 50C

income likely to have escaped assessment is more than Rs 50,00,000/- taking into consideration the provisions of 1st proviso to section 149(1)(b) of the ITA, 1961. As such the appellant contends that, the present re- assessment proceedings are bad in law and ought to be quashed

Income Tax Officer, Ward-8(1), Hyderabad vs. Dagumati Swathi, Hyderabad

In the result, the appeal filed by the revenue being devoid and bereft of any substance is dismissed in terms of our aforesaid observations

ITA 1638/HYD/2025[2013-14]Status: DisposedITAT Hyderabad30 Jan 2026AY 2013-14

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 13Section 142(1)Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 151A

13/05/2021 (originally issued by the JAO, i.e., ITO, Ward-8(1), Hyderabad) was barred by limitation as the same, as per the unamended section 149(1)(b) of the Act for the year under consideration, i.e., AY 2013-14, could have been issued latest by 31/03/2020. 6. Ostensibly ... issued on 13.05.2021 by the Jurisdictional Assessing Officer, Ward-8(1), Hyderabad. The limitation for issue of notice under the unamended section 149(1)(b) had expired on 31.03.2020, and the Department has sought shelter under the Relaxation Act, 2020 and CBDT notifications extending limitation. Although the Hon'ble Supreme

Ramesh Babu Bejjala, Kothagudem vs. Income Tax Officer, Ward-1, Kothagudem

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

ITA 1010/HYD/2025[2015-16]Status: DisposedITAT Hyderabad30 Jan 2026AY 2015-16

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 149(1)(b)Section 348Section 44ASection 63A

following grounds of appeal: “1. The learned CIT(A) erred in upholding the Section 348 notice, which is unequivocally time-barred under Section 149(1)(b) of the Act. This section mandates that for reassessments Initiated beyond three years from the relevant assessment year, the escaped Income must exceed ... 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 8 Ramesh Babu Bejjala vs. ITO the Act a notice under section 148 of the Act for the AY 2015-16 could

Devanand Amarnath Parkar, Jogeshwari East, Mumbai vs. Income Tax Officer 41(4)(1), Kautilya Bhawan, Bkc, Bandra East

ITA 6462/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 147Section 148Section 148ASection 151Section 56(2)(viib)

relevant Assessment Year. Three years from the end of the Assessment Year 2017-18 lapsed on 31.03.2021. As per section 149(1)(b) of the Act (new regime), re-assessment proceedings could have been initiated after the expiry of three years from the end of the relevant Assessment Year only ... relevant assessment year i.e., AY 2017-18. 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

Bhushan Vasant Parelkar, Mumbai vs. Ward 41(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 6322/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jan 2026AY 2013-14

Bench: Smt Beena Pillai & Shri Girish Agrawalassessment Year: 2013-14 Bhushan Vasant Parelkar Income Tax Officer, A-204 Saikripa, Navghar Ward 41(2)(1), Road, Mulund East S.O, Vs Mumbai Mumbai - 400081 (Pan: Akdpp6556D) Appellant Respondent Present For: Appellant By : Shri Dharan Gandhi, Advocate Respondent By : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 21.01.2026 Date Of Pronouncement : 30.01.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2025-26/1079866363(1), Dated 22.08.2025, Passed Against The Assessment Order By Ito, Ward-41(2)(1),, U/S. 147 Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 31.05.2023 For Assessment Year 2013-14. 2. Grounds Taken By The Assessee Are Reproduced As Under: “The Ld. Cit(A) Erred In Confirming The Action Of Ld. Ao Of Reopening The Assessment U/S 147 Although The Reopening Is Time Barred & Hence Bad In Law. Bhushan Vasant Parelkar Ay 2013-14

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 147Section 148Section 148ASection 149(1)(b)Section 50C

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 ... regime. Thus, first proviso to section 149 under the new regime limits the retrospective operation to protect the interest of assessees. Section 149(1)(b) of the old regime provided a time limit of six years from the end of the relevant assessment year for issuing notice under Section

Sudhir Motiram Patil, Mumbai vs. ITO, Ward 3(2), Kalyan

In the result, the appeal by the assessee is allowed

ITA 6190/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalsudhir Motiram Patil C/O Hukumchand Jain, 16Th Floor, D Wing, Trade World Kamala Mills Compound, Senapati Bapat Marg, Lower Parel, Mumbai, Maharashtra - 400013 ............... Appellant Pan: Avvpp1813G V/S Income Tax Officer, Ward-3(2), Rani Mansion, Murbad Road, ……………… Respondent Kalyan, Maharashtra – 421301 Assessee By : Shri Himanshu Gandhi, Ca Revenue By : Shri Pravin Salunkhe, Sr.Dr

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 115BSection 144BSection 147Section 148Section 148ASection 149(1)Section 149(1)(b)Section 151Section 151ASection 234A

erred in confirming reopening of assessment without considering the fact that the proceedings for AY 2017-18 are time barred as per section 149(1)(b) of Income Tax Act, 1961. 3. On the facts and circumstances of the case and law, the Ld CIT(A) erred in confirming reopening ... shall be issued after the expiry of three years from the end of the relevant assessment year. The provisions of section 149(1)(b) of the Act provides an exception and states that notice under section 148 of the Act can be issued after three years, but not after

Akshay Deepak Talim, Mumbai vs. Income Tax Officer Ward 4(1)(1), Mumbai

ITA 5130/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jan 2026AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Suhas Kulkarnai, AdvFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 147Section 148Section 148ASection 149Section 69A

under section 148 shall be issued after the expiry of 3 years from the end of the relevant assessment year. The provisions of section 149(1)(b) of the Act provides an exception and states that notice under section 148 of the Act can be issued after 3 years ... escaped assessment for the year under consideration which is more than Rs. 50,00,00. Hence, this case falls within the provisions of section 149(1)(b) of the IT Act. Further, provisions of section 151 of the IT Act are also reproduced as under: - "151. Specified authority

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 5020/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jan 2026AY 2016-17

Bench: Shri Sandeep Gosain

Section 147Section 148Section 148ASection 250Section 69A

notice was issued on the assumption that the cash deposit was Rs. 59.75 lacs by invokine extended period of limitation available under section 149(1)(b), as a fact, it was found that the same was Rs. 33.62 lacs only proceedings as the limitation under section 149(1 ... assumption of the income escaped to the tune of Rs.2 Crores by invoking extended period of limitation available under section 149(1)(b) is invalid. 3. Validity of notice u/s. 148 of the Act: - i. Your Honour may note that Ld. JAO has issued the notice

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

notice was issued on the assumption that the cash deposit was Rs. 59.75 lacs by invokine extended period of limitation available under section 149(1)(b), as a fact, it was found that the same was Rs. 33.62 lacs only proceedings as the limitation under section 149(1 ... assumption of the income escaped to the tune of Rs.2 Crores by invoking extended period of limitation available under section 149(1)(b) is invalid. 3. Validity of notice u/s. 148 of the Act: - i. Your Honour may note that Ld. JAO has issued the notice