M/S CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

147 within the period prescribed under section 149 read with section 150 of the Act. We are fortified in our view by a decision of the Apex Court in the case of K. M. Sharma v. ITO [2002] 254 ITR 772 wherein the Apex Court had considered the amendment made in sub-section (1) of section

KHURSHID AHMAD DAR,JAMMU AND KASHMIR, INDIA vs. ITO WARD, UDHAMPUR, UDHAMPUR

In the result, the appeal of the assessee is allowed

Bench: Dr. Mitha Lalmeena, Hon'Ble & Shri Udayan Das Gupta, Hon'Blekhurshid Ahmad Dar Vs. Ito, Ward, Nully Poshwari Turkawangam, Udhampur Shopia, 192305, Jammu & Kashmir, India.Pin 192305. Pan No. Awmpd5664K Assessee By Shri Rohit Kapoor, Adv. & Shri V.S. Aggarwal, Itp. Revenue By Mrs. Roshanta Kumari Meena, Cit Dr. Date Of Hearing 23.09.2025. Date Of Pronouncement To. [1 .2025. Order Dr. Mitha Lal Meena, A.M.:

147 is bad in law as the notice under section 148 was issued on 13.04.2021 without adheringto the new procedure applicable from 01.04.2021, specifically without complying with the provisions of section 148A. 5. We have heard both the sides and perused the material on record. We find that the notice u/s 148 dated 28.03.2021, was issued on 13.04.2021, as contended

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

In the result, the appeal filed by the assessee is allowed for statistical purpose

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

u/s 132(1)( c ) which has to have been discovered during search. “Assessment of Income of any other person. 153C. [(1) [Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, "belongs

SHRI HARJINDER SINGH ,BATHINDA vs. INCOME TAX OFFICER, WARD-2(1), BATHINDA

Bench: Sh. Ravish Sood & Dr. M. L. Meena

reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. Copy of the form for recording the reasons for initiating the proceedings under section 148 of the Act and for obtaining the approval of the JCIT

SHRI BRIJINDERPAL SINGH BHULLAR,MOHALI vs. INCOME TAX OFFICER WARD- 1 (3), BATHINDA

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

Bench: Sh. Ravish Sood & Dr. M. L. Meena

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, [***], as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

SHRI BARJINDERPAL SINGH BHULLAR,MOHALI vs. INCOME TAX OFFICER WARD- 1 (3), BATHINDA

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

Bench: Sh. Ravish Sood & Dr. M. L. Meena

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, [***], as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

SOM RAJ,PATHANKOT vs. THE INCOME TAX OFFICER, PATHANKOT

Bench: Shri. Ravish Sood & Dr. M. L. Meena

reassessment proceedings under section 147 r.w.s 148 of the Act, it is not in dispute that the A.O. is required to get the approval of the competent authority i.e; JCIT in the present case. Copy of the form for recording the reasons for initiating the proceedings under section 148 of ITA No. 628/Asr/2016

SHRIMATI. HARBHAJAN KAUR,JALANDHAR vs. INCOME TAX OFFICER WARD -1 (20, JALANDHAR

In the result, the appeal of the assessee is allowed

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 of the act is not enough as it has to be proved that notice under section 148 of the act was served upon the assessee and similar is the position of the service of notice under section 143 (2) and 142 (1). The learned council has filed an affidavit as annexure in support of the submissions that neither notice

SH. JOGINDER SINGH S/O. SH. GURDIAL SINGH,BATHINDA vs. INCOME TAX OFFICER, BATHINDA

Appeal of the assessee is disposed of in the terms indicated as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

u/s 147 of the act. The section 150(1) of the act states that Notwithstanding anything contained in section 149, the notice under section 148 may be issued at any time for the purpose of making an assessment or reassessment

SHRI KIRANJIT SINGH,AMRITSAR vs. INCOME TAX OFFICER WARD -4(3), AMRITSAR

In the result, the appeal of the assessee bearing ITA No

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.723/Asr/2019 Assessment Year: 2010-11

section 149 of income tax act, 1961. 6. That no valid notice u/s 148 is ever served to justify that the reassessment proceedings is as per law. I.T.A. No.723/Asr/2019 5 Assessment Year: 2010-11 7. That on the facts and circumstances of the case service of notice u/s 148 by affixture is illegal, bad in law and is liable

INCOME TAX OFFICER WARD -2 (1), AMRITSAR vs. MS. SAVITA BANSAL, THROUGH LEGAL HEIR SH. PARVEEN KUMAR BANSAL, AMRITSAR

In the result, the revenue’s appeal stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm 1. आयकर अपील सं. / Ita No. 240/Asr/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Income Tax Officer Smt. Savita Bansal Ward-2(1) बनाम/ (Through L/H Shri Parveen Kumar Bansal) Amritsar 143001 H.No. 272, Green Avenue Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Cross Objection No. 1/Amritsar/2024 (In Ita No. 240/Asr/2023) (िनधा"रण वष" / Assessment Year: 2016-17) Smt. Savita Bansal Income Tax Officer बनाम/ (Through L/H Shri Parveen Kumar Bansal) Ward-2(1) H.No. 272, Green Avenue Amritsar 143001 Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Dr Rakesh Gupta (Advocate) –Ld. Ar ""थ"कीओरसे/Respondent By : Shri B. Srinivas Kumar (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 10-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () Aforesaid Appeal By Revenue For Assessment Year (Ay) 2016- 1. 17 Arises Out Of An Order Of Ld. Commissioner Of Income Tax

147 of the Act. The want of valid notice affects the jurisdiction of the Assessing Officer to proceed with the assessment and thus, affects the validity of the proceedings for assessment or reassessment. A notice issued under section 148 of the Act against a dead person is invalid, unless the legal representative submits to the jurisdiction of the Assessing Officer

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 taxmann.com 399 (SC) “11. As per the provisions of Section 153A, in case of asearch under Section 132 or requisition under Section132A, the AO gets the jurisdiction to assess or reassessthe ‘total income’ in respect of each assessment yearfalling within six assessment years. However, it isrequired to be noted that as per the second proviso toSection 153A, the assessment

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 taxmann.com 399 (SC) “11. As per the provisions of Section 153A, in case of asearch under Section 132 or requisition under Section132A, the AO gets the jurisdiction to assess or reassessthe ‘total income’ in respect of each assessment yearfalling within six assessment years. However, it isrequired to be noted that as per the second proviso toSection 153A, the assessment

MEASAGE NARULA SOLVEX PRIVATE LIMITED,MOGA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 taxmann.com 399 (SC) “11. As per the provisions of Section 153A, in case of asearch under Section 132 or requisition under Section132A, the AO gets the jurisdiction to assess or reassessthe ‘total income’ in respect of each assessment yearfalling within six assessment years. However, it isrequired to be noted that as per the second proviso toSection 153A, the assessment

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 taxmann.com 399 (SC) “11. As per the provisions of Section 153A, in case of asearch under Section 132 or requisition under Section132A, the AO gets the jurisdiction to assess or reassessthe ‘total income’ in respect of each assessment yearfalling within six assessment years. However, it isrequired to be noted that as per the second proviso toSection 153A, the assessment

M/S NARULA OIL & FATS PRIVATE LIMITED,AHEMDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 taxmann.com 399 (SC) “11. As per the provisions of Section 153A, in case of asearch under Section 132 or requisition under Section132A, the AO gets the jurisdiction to assess or reassessthe ‘total income’ in respect of each assessment yearfalling within six assessment years. However, it isrequired to be noted that as per the second proviso toSection 153A, the assessment

MEASAGE NARULA SOLVEX PRIVATE LIMITED,MOGA vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE , AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 taxmann.com 399 (SC) “11. As per the provisions of Section 153A, in case of asearch under Section 132 or requisition under Section132A, the AO gets the jurisdiction to assess or reassessthe ‘total income’ in respect of each assessment yearfalling within six assessment years. However, it isrequired to be noted that as per the second proviso toSection 153A, the assessment

MEASAGE SAT KARTAR SOLVEX PRIVATE LIMITED,FEROZEPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, the appeals of the revenue are dismissed and appeals of assessee are allowed in the terms indicated above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

149 taxmann.com 399 (SC) “11. As per the provisions of Section 153A, in case of asearch under Section 132 or requisition under Section132A, the AO gets the jurisdiction to assess or reassessthe ‘total income’ in respect of each assessment yearfalling within six assessment years. However, it isrequired to be noted that as per the second proviso toSection 153A, the assessment