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

3) of section 153 of the Act would not be attracted. It will be attracted I.T.A. No. 356/Asr/2017 19 Assessment Year: 2006-07 only when the notices under section 147 of the Act has been issued to initiate proceeding under section 147 within the period prescribed under section 149 read with section 150 of the Act. We are fortified

SHRI TARLOCHAN SINGH,MANSA vs. INCOME TAX OFFICER WARD-1(4), MANSA

In the result, both the appeals of the assessees are allowed

u/s 143(3) dated 20/12/2017. 3. The A.O. relied solely upon the sale deed dated 15.07.1981 for computing the FMV of the land as on 01.04.1981 for the purpose of computation of capital gain. The copy of the subject sale deed dated 15.07.1981 was neither provided nor confronted to the assessee during the course of assessment proceedings

SHRI NAROTAM SINGH,MANSA vs. INCOME TAX OFFICER WARD -1(4), MANSA

In the result, both the appeals of the assessees are allowed

u/s 143(3) dated 20/12/2017. 3. The A.O. relied solely upon the sale deed dated 15.07.1981 for computing the FMV of the land as on 01.04.1981 for the purpose of computation of capital gain. The copy of the subject sale deed dated 15.07.1981 was neither provided nor confronted to the assessee during the course of assessment proceedings

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.:

reassessment. 6. It is also noted that the notice u/s 148 and notices u/s 142(1) dated 04.10.2021 and 29.11.2021 were not served on the registered email ID i.e. Izeeshankhurshidll@gmail.com' of the appellant. In our view, the service of notice is an essential condition to complete the act of issuance which has been complied with on 13.04.2021 i.e. after

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 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

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

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

3), Bathinda ITA Nos. 671 & 672/Asr/2019 – A.Y 2008-09 the Act which shall have a material bearing on the adjudication of the controversy in hand. As per the mandate of Section 148 of the Act, the A.O, before making an assessment, reassessment or re-computation under Sec.147, shall serve on the assessee a notice requiring him to furnish within

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

3), Bathinda ITA Nos. 671 & 672/Asr/2019 – A.Y 2008-09 the Act which shall have a material bearing on the adjudication of the controversy in hand. As per the mandate of Section 148 of the Act, the A.O, before making an assessment, reassessment or re-computation under Sec.147, shall serve on the assessee a notice requiring him to furnish within

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

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 or recomputation in consequence of or to give effect to any finding or direction contained in an order passed

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

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