ROSHA ALLOYS P LIMITED, AMLOH ROAD, VILLAGE TURAN, MANDI GOBINDGARH,PUNJAB vs. DCIT CENTRAL CIRCLE 1, LUDHIANA, PUNJAB

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked in the absence

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked in the absence

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked in the absence

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, LUDHIANA , LUDHIANA vs. ROSHA ALLOYS PVT. LTD., MANDI GOBINDGARH

In the result, the appeals filed by the Revenue are dismissed,\nwhereas the appeals of the assessee are allowed

reassessment under Sections 147 and 148 of the\nAct, the existence of information suggesting escapement of income\ncontinues to be a foundational jurisdictional requirement. The Hon'ble\nCourt clarified that the benchmark under the amended law remains\naligned with the earlier threshold of “reason to believe,” and that the\npower under Section 147 cannot be invoked in the absence

RAJESH KHANNA,NEELKANTH PLYWOOD, YAMUNANAGAR vs. INCOME TAX OFFICER, WARD-3, INCOME TAX OFFICER, YAMUNANAGAR

In the result, the assessee's appeal in ITA

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2021-22/1042149336(1) dated 30/03/2022 and annexed herewith for reference. 2. I, therefore, propose to assess or reassess

INCOME TAX OFFICER, YAMUNA NAGAR vs. RAJESH KHANNA, YAMUNA NAGAR

In the result, the assessee's appeal in ITA

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

section 148A of the Act has been passed in such case vide DIN ITBA/AST/F/148A/2021-22/1042149336(1) dated 30/03/2022 and annexed herewith for reference. 2. I, therefore, propose to assess or reassess

GURJIT SINGH,ROPAR vs. INCOME TAX OFFICER, RUPNAGAR

Appeal stand allowed accordingly

Bench: Tribunal.

section 148A of the Act. The provisions is intended with an object of achieving efficiency, transparency and accountability inter alia by eliminating the interface between the income tax authority, optimizing utilization of the resources through economies of scale and functional specialization, and by introducing a team based assessment, reassessment

ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

section 148A of the Act. The provisions is intended with an object of achieving efficiency, transparency and accountability inter alia by eliminating the interface between the income tax authority, optimizing utilization of the resources through economies of scale and functional specialization, and by introducing a team based assessment, reassessment

ANUP KUMAR AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1019/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Sh. Anup Kumar Aggarwal Acit (Central) बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Adjpk-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Additions Of Rs.10.95 Lacs U/S 69 & Another Addition Of Rs.16.21 Lacs U/S 69A. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

section 148A of the Act. The provisions is intended with an object of achieving efficiency, transparency and accountability inter alia by eliminating the interface between the income tax authority, optimizing utilization of the resources through economies of scale and functional specialization, and by introducing a team based assessment, reassessment

POOJA AGGARWAL,PANCHKULA vs. ACIT(CENTRAL) SHIMLA, SHIMLA

Appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1026/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Ms. Pooja Aggarwal Acit Central बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abnpa-6660-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca)A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Substantive Addition Of Rs.16.21 Lacs & Protective Addition Of Rs.10.95 Lacs. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

section 148A of the Act. The provisions is intended with an object of achieving efficiency, transparency and accountability inter alia by eliminating the interface between the income tax authority, optimizing utilization of the resources through economies of scale and functional specialization, and by introducing a team based assessment, reassessment

KUSUM MITTAL,SANGRUR vs. INCOME TAX OFFICER, WARD - SANGRUR, SANGRUR

In the result, the appeal of the assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 148A(d), the reassessment order passed under section 147 read with section 144B, and the appellate order of the CIT(A) all stand

AMARJIT SINGH,LUDHIANA vs. INCOME TAX OFFICER,WARD 6(1) LUDHIANA, LUDHIANA

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

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 1171 /Chd/2024 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Amarjit Singh बनाम The ITO C/o V V Bhalla & Company Ward 6(1) SCF-39, Rishi Nagar Main Market, Ludhiana Adjoining Subway, Ludhiana-141001, Punjab स्थायी लेखा सं./PAN NO: ABTPS8558B अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से / Assessee by : Shri Pankaj Bhalla, C.A राजस्व की ओर से/ Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr

148A of the Act. 4. That the L.d. C.I.T.(A), NFAC, Delhi has failed to appreciate that the notice u/s 148 is in the contravention to section 151 of the Income Tax Act, 1961. 5 That the L.d. C.I.T. (A), NFAC, Delhi has failed to appreciate that the Approval taken u/s 151 of the Income Tax Act, 1961 is illegal

JOINT COMMISSIONER OF INCOME TAX (IN SITU) CIRCLE-I, , LUDHIANA vs. KAPIL THAPAR, LUDHIANA

In the result, appeal of the Department is dismissed and Cross

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

reassess the income of the other person in accordance with the provisions of section-153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the] determination of the total income of such other person for six assessment years! immediately preceding the assessment year relevant to the previous

DCIT, CC-3, LUDHIANA, KITCHLU NAGAR vs. MANI RAM BALWANT RAI HUF, CIVIL LINES

In the result, Cross Objection filed by the assessee is allowed and appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 The Dcit, Mani Ram Balwant Rai, Huf, Central Circle-3, Vs Civil Lines, Opposite Session Court(Old) Kitchlu Nagar, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent & C.O. 43/Chd/2024 In आयकर अपील सं./ Ita No. 1042/Chd/2024 "नधा"रण वष" / Assessment Year: 2019-20 Mani Ram Balwant Rai, Huf, The Dcit, Civil Lines, Opposite Session Court(Old) V Central Circle-3, Ludhiana. S Kitchlu Nagar, Ludhiana. "थायी लेखा सं./Pan No: Aaghm1535C अपीलाथ"/Appellant ""यथ"/Respondent Revenue By : Smt. Kusum Bansal, Cit Dr Assessee By : Shri Pankaj Bhalla, Ca & Shri Hunny Bajaj, Advocate Date Of Hearing : 17.07.2025 Date Of Pronouncement : 01.09.2025 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

reassessment or re- computation under section 147 or issuance of notice under section 148 81 [or conducting of enquiries or issuance of show-cause notice or passing of order under section 148A

INCOME TAX OFFICER, WARD-1, JIND, JIND vs. VIKAS JAIN, JIND

In the result, the assessee succeeds in its cross-objection

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.838/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Income Tax Officer Shri Vikas Jain बनाम/ Ward 1 Nav Bharat Steel & General Industries Vs. Jind-126102. Indira Bazar, Jind-126102. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aeqpj-3689-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Co No. 28/Chandi/2025 [In Ita No.838/Chandi/2024) Shri Vikas Jain Income Tax Officer बनाम/ Nav Bharat Steel & General Industries Ward 1 Vs. Indira Bazar, Jind-126102. Jind-126102. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aeqpj-3689-E (Cross Objector) : (Respondent) Assessee By : Shri Suresh Gupta (Ca) – Ld. Ar Revenue By : Smt. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 01-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 11/11/2025

148A by the AO i.e. ITO is invalid, illegal and without jurisdiction. 2. The reassessment is invalid and without restriction as the notice u/s 148 dated 31.03.2022 has been issued by JAO in violation of provisions of Section

AMAN ALLOYS PRIVATE LIMITED SIRHIND SIDE MANDI GOBINDGARH,PUNJAB vs. THE ASSESSMENT UNIT NFAC DELHI JAO THE INCOME TAX OFFICER WARD-2, MANDIGOBINDGARH , PUNJAB

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

Bench: The Cit(A). While The Delay Was Condoned, The Cit(A) Dismissed The Appeal On Merits Due To The Assessee’S Persistent Failure To Respond To Multiple Notices Issued During Appellate

reassessment proceedings, particularly compliance with Section 148A and the time limit under Section 149. Further, the AO shall verify whether

ARUN KUMAR,LUDHIANA vs. ITO WARD 6(1), LUDHIANA

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

section 148A of the Act. 3.1 In the reassessment proceedings, the Assessing Officer noticed that the total credits in the said

INCOME TAX OFFICE, WARD-I MANDI GOBINDGARH HQ SIRHIND vs. GOPAL KRISHAN BANSAL, AGGARWAL STEEL TUBES

In the result, appeal of the Assessee is allowed and cross appeal filed by the Revenue is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

section 148A of the Act. 4. Copy of notice issued u/s 148 of the Act dt. 8-9 29.07.2022 as per New Regime JUDGMENT RELIED UPON 5. Judgment in the case of Hitesh Ramniklal Shah Vs. 10-19 Assistant Commissioner of Income-tax as reported in (2025) 180 taxmann.com 642(Bombay) vide order dt. 11.11.2025 6. Judgment in the case