BADRINATH SALES PRIVATE LIMITED,ADITYAPUR, WEST SINGHBHUM vs. DCIT/ACIT CIRCLE 1 JSR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

reassessment proceedings are barred by limitation due to delayed service of notice under Section 148. 2. Whether the additions on account

KROSS LIMITED,JAMSHEDPUR vs. PCIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

148(2). This, however, will not obviate the bar of limitation under section 263(2). The invocation of the jurisdiction under section 263(2) was barred by limitation”. 9. In the instant case before us also the issue on which the ld. PCIT proposed the revision of reassessment

MARS MERCANTILES PVT.LTD.,DHANBAD vs. ASSISTANT COMMISSIONE OF INCOME TAX, CENTRAL CIRCLE, DHANBAD, DHANBAD

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2012-13

reassess such income, which he has reason to believe, has escaped assessment and also any other income, chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section; and (iv) though the notice under section 148(2

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT, JAMSHEDPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal

148 though delayed, has been taken into account, it is incumbent upon the Ld. AO to issue a notice u/s. 143(2) which otherwise vitiates the entire assessment proceedings. Requirement of issuing notice u/s. 143(2) cannot be dispensed with. Accordingly, the reassessment proceedings undertaken by the Ld. AO and the impugned reassessment order passed thereafter are liable

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT,CIRCLE-1(1),, JAMSHEDPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal

148 though delayed, has been taken into account, it is incumbent upon the Ld. AO to issue a notice u/s. 143(2) which otherwise vitiates the entire assessment proceedings. Requirement of issuing notice u/s. 143(2) cannot be dispensed with. Accordingly, the reassessment proceedings undertaken by the Ld. AO and the impugned reassessment order passed thereafter are liable

MISRILALL JAIN & SONS,SINGHBHUM WEST vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result the appeal filed by the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.468/Ran/2024 Assessment Year: 2017-18 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 30.07.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

148 of the Act can be framed only on the issues stated in the show-cause notice issued under section 148A(b) of the Act and no addition beyond such issues is permissible in law. Respectfully following the said binding precedent, we hold that the reassessment framed on issues beyond the scope of the notice issued under section 148A

HIRALAL AGENCIES PVT. LTD.,,RANCHI vs. DCIT, CIRCLE-1, RANCHI

Appeal of the assessee is allowed

Bench: the Ld. CIT(A) where appeal of the assessee was dismissed sustaining the order of the AO.

148 of the Act was issued on 11.08.2017, i.e., beyond four years from the end of A.Y. 2011–12, and the reasons recorded do not mention any failure on the part of the assessee, the reopening is barred by limitation and invalid in law. 9. Accordingly, the reassessment order passed under Section 147 read with Section

SMITA,RANCHI vs. ITO WARD 3(4),, CHAIBASA

The appeal of the assessee is allowed

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

2. Brief facts of the case are that the assessee filed his return of income for the assessment year 2018–19 declaring total income of ₹6,07,870. Subsequently, a notice under section 148 of the Act was issued on the ground that the assessee had sold a flat for a consideration of ₹30 lakhs, whereas the stamp duty value

BISHNU TRANSPORT COMPANY,DHANBAD vs. DCIT/ACIT, CIRCLE-1,, DHANBAD

In the result, the appeal of the assessee is allowed

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

148 of the Act and the consequent reassessment order passed under section 147 of the Act are bad in law and void ab initio. Once the reassessment itself is quashed on jurisdictional grounds, the additions made therein do not survive and are not required to be adjudicated on merits. 9. In view of the above facts and settled legal position

KULDIP SINGH,RANCHI vs. DCIT/ACIT, CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.180/Ran/2025 Assessment Year: 2014-15 Kuldip Singh…………………….……….……...................……….……Appellant The Avenue Vishnupuri Marg, Upper Burdwan Compound, Lalpur, Ranchi- 834001. [Pan: Agjps6921P] Vs. Dcit/Acit, Circle-1, Ranchi…...…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 10, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 06.03.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

section 148 of the Act dated 22.11.2019 is barred by limitation. Consequently, the assessment framed pursuant thereto is void ab initio. Accordingly, we quash the reassessment proceedings and allow the appeal of the assessee. 7. In the result, the appeal of the assessee is allowed. Kolkata, the 10th February, 2026. [Ratnesh Nandan Sahay] [Sonjoy Sarma] Accountant Member Judicial Member Dated

ARVIND KUMAR MISHRA,JAMSHEDPUR vs. ITO 1(1), JAMSHEDPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.229/Ran/2024 Assessment Year: 2017-18 Arvind Kumar Mishra… ….…………….……...................……….……Appellant 22/20, Mishra Niwas, Kharangajhar, Near Hanumanmandir Road Telco, Jamshedpur, Jharkhand – 831004. [Pan: Agdpm2983R] Vs. Ito, Ward-1(1)…………………...…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 02, 2026 Date Of Pronouncing The Order : February 04, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 02.06.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

148, the assessee filed the return of income declaring total income of ₹2,34,920 from business, with gross receipts of ₹1,06,82,530. Thereafter, notice under section 142(1) of the Act was issued and the assessment was completed I.T.A. No.229/Ran/2024 Arvind Kumar Mishra under section 147 read with section 144B of the Act. During the assessment proceedings

MANISH AGARWAL,BALLYGUNGE vs. ACIT, CENTRAL CIRCLE-2, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.16/Ran/2024 Assessment Year: 201-12 Manish Agarwal……….…………….…….…............................……….……Appellant 35A, Tirumala Apartment, Ballygunge Park, Kol- 700019. [Pan: Acdpa1176E] Vs. Acit, Central Circle-1, Ranchi......…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Sunit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 28.11.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That A Search & Seizure Operation Under Section 132 Of The Act Was Conducted In The Case Of The Assessee Group On 23.10.2019. Pursuant To The Said Search, The Assessing Officer (Ao) Issued A Notice Under Section 153A Of The Act Calling Upon The Assessee To File Its Return Of Income For Six Assessment Years Preceding The Year Of Search. In Response To The Notice Under Section 153A, The Assessee Filed Its Return Of Income For Assessment Year 2011–12, Declaring A Total Income Of ₹6,95,180/-. During The Course Of Assessment Proceedings, Several Statutory Notices Were Issued To The Assessee, Which

148, Section 149, Section 151 and Section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are I.T.A. No.16/Ran/2024 Manish Agarwal requisitioned under section 132-A after the 31st day of May, 2003, the Assessing Officer shall-- (a) issue notice to such person requiring

ABHISHEK GOURASARIA,JAMSHEDPUR vs. ACIT , JAMSHEDPUR

In the result, consequential assessment order also stands quashed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayabhishek Gourasaria, A.C.I.T., 118, Flat No. 2B, Surabhi Apartment, K Jamshedpur Vs. Road, Bistupur, Jamshedpur-831001. Pan No. Adwpg 2149 R Appellant/ Assessee Respondent/ Revenue

2. CIT v. India Terminal Connector System-Ltd. ITA No. 6430 of 2011. 3. Phool Chand Bajrang Lal V. Income-tax Officer (1993) 203 ITR 456 SC: 4. CIT V. Pradeep Kumar Gupta (2008) 303 ITR 95; Sec 153C read as under- "Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, JAMSHEDPUR, JAMSHEDPUR vs. BENKO TRADERS PRIVATE LIMITED, KOLKATA

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

148 was issued the assessee filed its return declaring the same income I.T.A. No.436/Ran/2024 Benko Traders Pvt. Ltd as earlier. Assessee had filed objections to reopening but rejected. Statutory notices under sections 143(2) and 142(1) were issued and complied with. According to the AO, income of ₹1,64,60,100 representing sale proceeds of shares

SARYU DEVI,RANCHI vs. ITO, WARD-1(1), RANCHI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.251/Ran/2025 Assessment Year: 2020-21 Saryu Devi…..………...…………….…….…............................……….……Appellant W/O Hira Nath Singh, Neori, Vikas, Sadar Ranchi, Jharkhand- 835217. [Pan: Geppd1201D] Vs. Ito, Ward-1(1), Ranchi…..….....…..…..….........……........……...…..…..Respondent Appearances By: Shri M. K. Choudhury, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : December 22, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 10.06.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is An Individual Lady, Residing In A Village Area. She Had Not Filed Any Return Of Income For The Assessment Year 2021–22 As, According To Her, She Had No Taxable Income. The Assessee Was Not Registered On The Income-Tax E-Filing Portal During The Relevant Period. Her E-Filing Registration Was Done For The First Time On 09.03.2025. The Ao Received Information Through The Risk Management Strategy (Rms) That The Assessee Had Purchased Immovable Property For A Consideration Of ₹30,70,000. Based On This Information, Proceedings Under Section 147 Of The Act Were Initiated After Following

148 of the Act is a jurisdictional requirement. In absence of valid service, the reassessment I.T.A. No.251/Ran/2025 Saryu Devi proceedings cannot be sustained. Therefore, we hold that the reassessment proceedings are invalid in law. 8. Even otherwise, on merits, we find that the alleged transaction is between husband and wife and the revenue has not brought any evidence to show

NAVEEN SINGH,JAMSHEDPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

148. Thereafter, multiple notices under section 142(1) were issued, including final opportunity notices, which were duly served but remained unanswered. I.T.A. No.413/Ran/2024 Naveen Singh Even notices served physically through notice server did not evoke any response. Accordingly, the AO completed the assessment under section 147 read with section 144, based on material available on record. The reasons recorded

SUBIR MANDAL,JAMSHEDPUR vs. ITO WARD 3(4), CHAIBASA, JAMSHEDPUR

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Ratnesh Nandan Sahayi.T.A. No. 188/Ran/2025 Assessment Year: 2017-2018 Subir Mandal,….…………………………………..Appellant 61, Parsudih, Pramathanagar, Jamshedpur-831001, Jharkhand [Pan:Anfpm1717N] -Vs.- Income Tax Officer,……………………………...Respondent Ward-3(4), Chaibasa, 47, Ch Area, Jamshedpur-831001, Jharkhand Appearances By: Shri Akshay Ringasia, A.R., Appeared On Behalf Of The Assessee Shri Khubchand T. Pandya, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 21, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

reassessment proceeding under section 148. However, notice u/s 148 and subsequent notices under section 142(1) could not be acted upon by the assessee. The assessee purchased an immovable property jointly owned along with his wife. The total consideration jointly paid was Rs.20,00,000/- where the assessee paid only a portion of consideration and the rest was paid

LAL BAHADUR SINGH,DHANBAD vs. DCIT CENTRAL CIRCLE, DHANBAD

In the result, appeals of the assesses are allowed and appeals of the revenue are dismissed

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.90 To 94/Ran/2024 (निि ारण वर्ा / Assessment Years :2008-2009 To 2012-2013) Shri Kumbh Nath Singh, Vs Dcit, Central Circle, Dhanbad Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1598 K & आयकर अपील सं./Ita Nos.268 & 269/Ran/2024 (निि ारण वर्ा / Assessment Years :2010-2011 & 2012-2013) Acit, Central Circle, Dhanbad Vs Shri Kumbh Nath Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1598 K & आयकर अपील सं./Ita Nos.95 To 99/Ran/2024 (निि ारण वर्ा / Assessment Years :2008-2009 To 2012-2013) Vs Dcit, Central Circle, Dhanbad Shri Bharat Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1599 J & आयकर अपील सं./Ita Nos.100 To 106/Ran/2024 (निि ारण वर्ा / Assessment Years :2006-2007 To 2012-2013) Vs Dcit, Central Circle, Dhanbad Shri Lal Bahadur Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Aydps 0747 D & आयकर अपील सं./Ita Nos.265 To 267/Ran/2024 (निि ारण वर्ा / Assessment Years :2010-2011 To 2012-2013) Acit, Central Circle, Dhanbad Vs Shri Lal Bahadur Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Aydps 0747 D (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्ाारिती की ओर से /Assessee By : Shri Devesh Poddar, Advocate & Shri Sanjay Chatterjee, Ar राजस्व की ओर से /Revenue By : None(Adjournment Petition Filed) सुनवाई की तारीख / Date Of Hearing : 09/10/2025 घोषणा की तारीख/Date Of Pronouncement : 09/10/2025

reassessment within time can be treated as a valid assessment made within the period of limitation prescribed under section 153(2) of the Income Tax Act, 1961? In the present case, as the two notices under section 148

LAL BAHADUR SINGH,DHANBAD vs. DCIT, CENTRAL CIRCLE, DHANBAD

In the result, appeals of the assesses are allowed and appeals of the revenue are dismissed

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.90 To 94/Ran/2024 (निि ारण वर्ा / Assessment Years :2008-2009 To 2012-2013) Shri Kumbh Nath Singh, Vs Dcit, Central Circle, Dhanbad Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1598 K & आयकर अपील सं./Ita Nos.268 & 269/Ran/2024 (निि ारण वर्ा / Assessment Years :2010-2011 & 2012-2013) Acit, Central Circle, Dhanbad Vs Shri Kumbh Nath Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1598 K & आयकर अपील सं./Ita Nos.95 To 99/Ran/2024 (निि ारण वर्ा / Assessment Years :2008-2009 To 2012-2013) Vs Dcit, Central Circle, Dhanbad Shri Bharat Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1599 J & आयकर अपील सं./Ita Nos.100 To 106/Ran/2024 (निि ारण वर्ा / Assessment Years :2006-2007 To 2012-2013) Vs Dcit, Central Circle, Dhanbad Shri Lal Bahadur Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Aydps 0747 D & आयकर अपील सं./Ita Nos.265 To 267/Ran/2024 (निि ारण वर्ा / Assessment Years :2010-2011 To 2012-2013) Acit, Central Circle, Dhanbad Vs Shri Lal Bahadur Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Aydps 0747 D (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्ाारिती की ओर से /Assessee By : Shri Devesh Poddar, Advocate & Shri Sanjay Chatterjee, Ar राजस्व की ओर से /Revenue By : None(Adjournment Petition Filed) सुनवाई की तारीख / Date Of Hearing : 09/10/2025 घोषणा की तारीख/Date Of Pronouncement : 09/10/2025

reassessment within time can be treated as a valid assessment made within the period of limitation prescribed under section 153(2) of the Income Tax Act, 1961? In the present case, as the two notices under section 148