WAVES TRADELINE PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

The appeals of the assessee are allowed

sections": [ "147", "148", "148A", "148A(b)", "148A(d)", "149(1)", "151", "68" ], "issues": "Whether the notices for reassessment proceedings under

NA ROTO MACHINE & MOULDS INDIA,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 148 of the new regime, which are in pursuance of the deemed notices, ought to be issued within the time limit surviving under the Income Tax Act read with TOLA. A reassessment notice issued beyond the surviving time limit will be time-barred. [Emphasis supplied.] Na Roto Machine & Moulds India vs. ACIT Page

ITO, WARD-4(1)(3), AHMEDABAD vs. SHIVGANGA PROPERTY HOLDERS PVT. LTD, AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

Section 148A of the Act in reassessment cases. 8. We have carefully considered the grounds raised by the assessee, the arguments

SHIVGANGA PROPERTY HOLDERS PVT. LTD,AHMEDABAD vs. ITO, WARD-4(1)(3), AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

Section 148A of the Act in reassessment cases. 8. We have carefully considered the grounds raised by the assessee, the arguments

THE ITO, WARD-4(1)(3), AHMEDABAD vs. SHRI VIGHNAHARTA REALITY PVT. LTD., AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

Section 148A of the Act in reassessment cases. 8. We have carefully considered the grounds raised by the assessee, the arguments

DEEP SUDHIRBHAI SHETH (LEGAL HEIR OF SUDHIR HIMMATLAL SHETH),AHMEDABAD vs. ITO, WARD 3(2)(1), AHMEDABAD, AHMEDABAD

In the result the appeal of the assessee is allowed

Bench: S/Shri Sanjay Garg & Makarand V. Mahadeokarasstt. Year: 2016-17 Deep Sudhirbhai Sheth (Legal Heirs Ito, Ward-3(2)(1) Of Sudhir Himmatlal Sheth) Vs. Ahmedabad. Prop. Subhlaxmi Jewellers 3, Khodiyar Shopping Centre Nr.Ishanpur Bus Stand Ishanpur, Ahmedabad. Pan : Ainps 3786 Q (Applicant) (Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Shri Nitin Vishnu Kulkarnai, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 10/11/2025 घोषणा की तारीख /Date Of Pronouncement: 28/11/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

reassessment was void since both the notices under section 148A(b) and section 148 were issued to a person who had already

SHRI VIGHNAHARTA REALTY PVT. LTD,AHMEDABAD vs. THE ITO, WARD-4(1)(3), AHMEDABAD

The appeal of the Revenue is dismissed

Section 148A of the Act in reassessment cases.\n8.\nWe have carefully considered the grounds raised by the assessee, the\narguments

TUSHAR VIPINCHANDRA SHUKLA,AHMEDABAD vs. THE ITO, WARD-5(3)(2), AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purpose

Bench: Ms. Suchitra Kambleassessment Year 2019-20

reassessment proceedings is bad in law, as the Show Cause Notice was issued under section 148A(b) of the Act despite

MAHENDRAKUMAR CHUNILAL SANGHVI,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

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

Bench: or at the time of hearing of the appeal."

section 148A of the Act. Thus, Ld Counsel requested to quash the reassessment order as without jurisdiction and relied upon

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. MAHENDRAKUMAR CHUNILAL SANGHVI , AHMEDABAD

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

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

section 148A of the Act. Thus, Ld Counsel requested to quash the reassessment order as without jurisdiction and relied upon

SUNIL PIYUSH SHAH,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. -THE ITO, WARD-5(3)(2), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Kambleassessment Year 2019-20

reassessment proceedings itself is void ab initio, as the notice issued under section 148A(b) and the consequential order under

INFINITY INTERNATIONAL,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

148A(d) [Annexure-A1] of the IT Act, the notice dated 31.03.2022 under Section 148 of the IT Act [Annexure-A2], the assessment order dated 24.02.2023 under Section 147 read with Section 144 of the IT Act [Annexure-A3] and the consequential penalty orders and demand notices dated 24.08.2023 and 07.07.2023 [Annexures-A4, A5 and A6] are quashed." 4. Under

INFINITY INTERNATIONAL,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

148A(d) [Annexure-A1] of the IT Act, the notice dated 31.03.2022 under Section 148 of the IT Act [Annexure-A2], the assessment order dated 24.02.2023 under Section 147 read with Section 144 of the IT Act [Annexure-A3] and the consequential penalty orders and demand notices dated 24.08.2023 and 07.07.2023 [Annexures-A4, A5 and A6] are quashed." 4. Under

SHREE VISHVAMURTE TRADINVEST PRIVATE LIMITED,AHMEDABAD vs. ITO WARD 4 (1) (1), AHMEDABAD

In the result, the appeal filed by the assessee in ITA No

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

148A(d) of the Act as well as notice under section 148 of the Act was issued on 30.08.2022. However, considering the period of limitation from the date of issuance of notice under section 148 I.T.A Nos. 103 & 432/Ahd/2025 A.Y. 2017-18 Page No 7 Shree Vishvamurte Tradinvest Pvt. Ltd. vs. ITO read with TOLA upto 30.06.2021, the limitation

INCOME-TAX OFFICER, WARD-4(1)(1), AHMEDABAD , AHMEDABAD vs. SHREE VISHVAMURTE TRAD INVEST PRIVATE LIMITED, AHMEDABAD

In the result, the appeal filed by the assessee in ITA No

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

148A(d) of the Act as well as notice under section 148 of the Act was issued on 30.08.2022. However, considering the period of limitation from the date of issuance of notice under section 148 I.T.A Nos. 103 & 432/Ahd/2025 A.Y. 2017-18 Page No 7 Shree Vishvamurte Tradinvest Pvt. Ltd. vs. ITO read with TOLA upto 30.06.2021, the limitation

INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD, AHMEDABAD vs. AMBALIA HITESH CHHAGANLAL HUF, AHMEDABAD

In the result, both the appeals of the Revenue are dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamble

reassessment proceedings was raised orally on the ground that the sanction obtained under section 151 of the Act prior to issuance of notice under section 148 was not by the competent authority. We have considered the legal ground raised before us in view of the decision of the Hon’ble Supreme Court in the case of National Textile Corporation

INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD, AHMEDABAD vs. AMBALIA HITESH CHHAGANLAL HUF, AHMEDABAD

In the result, both the appeals of the Revenue are dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamble

reassessment proceedings was raised orally on the ground that the sanction obtained under section 151 of the Act prior to issuance of notice under section 148 was not by the competent authority. We have considered the legal ground raised before us in view of the decision of the Hon’ble Supreme Court in the case of National Textile Corporation

ANKUR CHANDRAKANT PATEL,MEHSANA vs. THE INCOME TAX OFFICER, WARD-1, MEHSANA

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

reassessment or recomputation under section 147, and subject to the provisions of section 148A, the Assessing Officer shall serve on the assessee