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

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

reassessment proceedings that the capital was introduced by way of transfer of ancestral land but the status has been mentioned as individual. In view of the above stated facts, the proceedings initiated u/s 147 are void-ab- initio and the notice u/s 147 may kindly be vacated. It is also prayed that the assessment proceedings may kindly be kept pending

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

147 shall apply as they apply for the purposes of that section.]” Insofar the mode and manner of service of a notice issued under Sec. 148 of the Act is concerned, the same can be traced in Sec. 282 of the Act and Rule 127 of the Income-tax Rules, 1962, which reads as under : “282 (1) The service

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

147 shall apply as they apply for the purposes of that section.]” Insofar the mode and manner of service of a notice issued under Sec. 148 of the Act is concerned, the same can be traced in Sec. 282 of the Act and Rule 127 of the Income-tax Rules, 1962, which reads as under : “282 (1) The service

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

147 (a) of the Act the Act. (2) If satisfaction is arrived at on the basis of any relevant material, such satisfaction cannot be assailed, Tilak raj bedi vs JCIT (2009) 319 ITR 385-P&H- The power of reassessment can be validly exercised if satisfaction is arrived at after following due procedure that income had escaped assessment. Such satisfaction

LATE. SH. GURMAIL SINGH.S/O. LATE SH. LAL SINGH,SRI MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

SH. ARASHPREET SINGH S/O LATE SH. GURMAIL SINGH,SHRI MUKATSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

SH. ARSPREET SINGH . S/O. LATE. SH. GURMAIL SINGH ,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE .II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CERCLE- II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

LATE. SH. GUMAIL SINGH . S/O. SH. LAL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

LATE. SH. GURMAIL SINGH S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

SH. ARASHPREET SINGH. S/O.LATE.SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX .CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

LATE. SH. GURMAIL. SINGH S/O. SH. LAL SINGH,SHRI MUKAT SAR vs. DY. COMMISSIONER OF 9INCOME TAX. CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

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

147 are void ab-initio as notice under section 148 was never served in accordance with the provisions of section 282 of the Income Tax Act, 1961. 8. That in the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) gravelly erred in upholding the proceedings under section 147/148 of the Income

AMBEY CONSTRUCTION COMPANY,BATHINDA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BATHINDA

In the result, the appeal of the assessee is allowed

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 121/Asr./2017 : Asstt. Year : 2011-12 Ambey Construction Company, Vs Asstt. Commissioner Of #21605, Street No. 7, Power House Income Tax, Circle-1, Road, Bathinda Bathinda (Appellant) (Respondent) Pan No. Aanfa7199K

section 282 of the IT Act, 1961. The specific objection was raised during the course of assessment proceedings and the same has not even not rebutted by the AO during assessment proceedings and ITA No. 121/Asr./2017 2 Ambey Construction Company this fact has even been admitted by him in the remand report. 3. The Ld. CIT(A) erred

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

282 Taxman 496 (All) : (2005) 149 Taxman 247 Pg. 53 to 58 case laws. f) Commissioner Of Income Tax Vs. Rajeev Sharma High Court Of Allahabad: Lucknow Bench (2010) 232 CTR (All) 303 : (2010) 192 Taxman 197 : (2010) 40 DTR 129 Pg. 59 to 71 case laws. g) Commissioner Of Income Tax Vs. Cebon India Ltd. High Court Of Punjab

SMT. ASHA CHHABRA,BATHINDA vs. INCOME TAX OFFICER, WARD - 1(1), BATHINDA

In the result, the ground no

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

reassessment proceedings were initiated to verify the source of investment in the purchase of plot and construction of house. Hence, the reasons to believe as recorded by the AO were infact reasons to suspect. d) The finding of the CIT(A) in para-3.2 that "At the stage of notice, it is 'the believe' of the AO based on facts