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)

reassessment U/S.144B r.w.s. 147 of the Act was completed by the FAO. The fact that the relevant material has not been provided to the assessee during the 148A proceedings is very much recorded by the Assessing Officer in the -Order u/s. 148A(d) of the Act dated.30.03.2022. However, the detailed reasons for the proposed reopening have been provided

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)

reassessment U/S.144B r.w.s. 147 of the Act was completed by the FAO. The fact that the relevant material has not been provided to the assessee during the 148A proceedings is very much recorded by the Assessing Officer in the -Order u/s. 148A(d) of the Act dated.30.03.2022. However, the detailed reasons for the proposed reopening have been provided

MANDEEP KAUR,FATEHABAD vs. ITO, WARD - 1, FATEHABAD

The appeal stand allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.630/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2016-17) Ms. Mandeep Kaur Ito Ward -1 बनाम/ Vs. Vpo Museh Ali Hizrawan, Khurd, To Fatehabad Rohtak - 124001 Fatehabad, Haryana – 125050 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Datpk-9813-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Mukesh Kumar Jain (Ca) – Ld. Ar (Virtual) ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 10.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.02.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016- 17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 17-02-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144Of The Act On30-04-2023. 2. The Ld. Ar, At The Outset, Urged Legal Ground No.4 To Assail The Jurisdiction Of Ld. Ao. In This Ground Of Appeal, It Has Been Pleaded That The Order Passed U/S 148A(D) As Well As Issue Of Notice U/S 148

147 r.w.s. 144of the Act on30-04-2023. 2. The Ld. AR, at the outset, urged legal ground no.4 to assail the jurisdiction of Ld. AO. In this ground of appeal, it has been pleaded that the order passed u/s 148A(d) as well as issue of notice u/s 148 2 Assessment Year: 2016-17 was without jurisdiction which make

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

reassessment order passed was illegal and invalid due to following:-\n1. Notice u/s 148 issued on 01.04.2021 is time barred for the above Assessment\nYear.\nRegarding the date of issue of notice, there is no date mentioned on ITBA\nportal when the notice was uploaded and column is left blank. The snapshot\nis as under:\nIncome Tax Portal, Government

INDO PACIFIC FINLEASE LTD,CHANDIGARH vs. PCIT- CHANDIGARH 1, CHANDIGARH

In the result, both the appeals are filed by the\nassessee are allowed

reassessment order passed was illegal and invalid due to following:-\n\n1. Notice u/s 148 issued on 01.04.2021 is time barred for the above Assessment Year.\nRegarding the date of issue of notice, there is no date mentioned on ITBA portal when the notice was uploaded and column is left blank. The snapshot is as under:\n\nIncome Tax Portal

DHARAMVIR SINGH ,VILLAGE THAMBER vs. ITO WARD 1 , AMBALA

In the result, the impugned order and the proceedings are unsustainable in law

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

147 by issue of notice u/s. 148 of the Income Tax Act, 1961 on 31/03/2022. In response to that assessee has filed return of income u/s.148 of the I.T. Act on 01.06.2022 with declaring income of Rs.1,78,180/-The assessee has shown source of income mainly from Rent and Interest. Assessee had deposited cash

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)

147 of the Act and assessment framed u/s 147/144B of the Act are invalid and deserve to be quashed as such. 7. That the information on the basis of which proceedings u/s 148 A were initiated is based only on borrowed information without application of mind much less independent application of mind and hence untenable. 8. That without prejudice

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)

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 to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

JAMYANG KHYENTSE YESHI,KANGRA, HIMACHAL PRADESH vs. ACIT, DCIT, C.R. BUILDING, CHANDIGARH

The appeal of the assessee is partly allowed

Bench: The Ld. Cit(A). The Ld. Cit(A), After Calling For A Remand Report Under Rule 46A, Recorded The Following Findings (Para 5.1 To 5.5 Of The Appellate Order):

147 to 153, in relation to both reopening u/s 148 and making reassessment, thus reassessment was bad in law and in procedure. 3. That notice u/s 148 dated 31.03.2021 was issued on 01.04.2021, therefore it would be governed by the re-assessment regime which came into effect on 01.04.2021, thus, assessment is not according to new procedure established

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)

147 was void-ab-initio in the violation of law settled in UOI vs. Rajeev Bansal 340 CTR 862(SC). The validity of notice issued uls 148 in the case of the assessee is bad in law as per facts as below which is similar facts, based on which notice issued u/s 148 treated as void-ab-initio

GOPAL KRISHAN BANSAL, MANDI GOBINDGARH,PUNJAB vs. ITO WARD -1, MANDI GOBINDGARH, SIRHIND

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)

147 was void-ab-initio in the violation of law settled in UOI vs. Rajeev Bansal 340 CTR 862(SC). The validity of notice issued uls 148 in the case of the assessee is bad in law as per facts as below which is similar facts, based on which notice issued u/s 148 treated as void-ab-initio

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 151A of the IT Act notified by CBDT through notification dated 29.03.2022 and therefore, the reassessment proceeding need to be quashed

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-

147 or for issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show-cause notice or passing order under 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

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)

147 or for issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show-cause notice or passing order under 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

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-

147 or for issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show-cause notice or passing order under 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

ASTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. WARYAM STEEL CASTING PRIVATE LIMITED, KANGANWAL ROAD

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

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

reassessment proceedings have not been provided. 2. That the order dated 10.05.2024 passed u/s 250 of the Act by the National faceless Appeal Centre (NFAC). Delhi is against law and (acts on the (lie in as much as he was not justified to uphold the action of the Ld. Assessing Officer. Assessment Unit. Income Tax Department in restricting the addition