This compilation indexes twelve recent judicial decisions from the Income Tax Appellate Tribunal (ITAT) and various High Courts in India, all engaging Section 148 of the Income Tax Act, 1961. It is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citable reference to current judicial activity around reassessment notices. Each entry is drawn from verified source data and is presented as a research index entry, not as legal commentary or advice.

Research index only. This page summarises publicly available judicial orders for information and research purposes. It does not constitute legal advice, and no reliance should be placed on it as a substitute for reading the full judgment or obtaining qualified professional counsel.

The statutory framework in one paragraph

Section 148 of the Income Tax Act, 1961 empowers an Assessing Officer to issue a notice to a taxpayer requiring the filing of a return of income where the Assessing Officer has reason to believe that income chargeable to tax has escaped assessment. The section operates in conjunction with Section 147, which sets out the substantive ground for reopening a completed assessment, and with Sections 148A, 149, and 151, which impose procedural requirements — including a pre-notice inquiry, limitation periods for issuance of the notice, and prior approval from a specified authority — before a valid notice under Section 148 can be issued.

The 12 rulings

1. Gunja Gupta, Jalaun vs ITO Ward-2(1)(5), Orai on 24 April, 2026

Bench: Income Tax Appellate Tribunal - Agra
Date: 24 April 2026
Sections engaged: 115B, 132(4), 133(1), 139(1), 147, 148, 4, 69A
Procedural / substantive ground: The appeal arose before the Agra Bench against an order of the Commissioner of Income Tax (Appeals), NFAC, Delhi, for Assessment Year 2013-14. The case involved a survey conducted under Section 133(1)(a) in the case of a connected party, with the reassessment proceedings under Section 148 flowing from findings during that survey. The matter concerned treatment of amounts under Section 69A in the context of the reopened assessment.

2. Torque Pharmaceuticals Private Limited vs DCIT, Central Circle-2, Chandigarh on 21 April, 2026

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 21 April 2026
Sections engaged: 1, 11, 110, 11U, 132, 143(3), 147, 148, 148B, 17, 2, 20, 36(1), 36(1)(iii), 37, 533, 56(2), 56(2)(x), 69C, 7
Procedural / substantive ground: This appeal before the Chandigarh Bench concerned reassessment proceedings for Assessment Year 2021-22 initiated following a search under Section 132. The case engaged a broad range of provisions including Section 148B, which governs approval requirements for reassessment orders in search cases, as well as provisions relating to unexplained expenditure under Section 69C and share premium issues under Section 56(2)(x).

3. Somnath Kannure, Pune vs Income Tax Officer Ward 1(1), Pune on 21 April, 2026

Bench: Income Tax Appellate Tribunal - Pune
Date: 21 April 2026
Sections engaged: 147, 148, 148A, 148A(d), 149, 151, 151(i), 151(ii), 250, 3, 3(1)
Procedural / substantive ground: The assessee filed this appeal against an order of the CIT(A) passed under Section 250 for Assessment Year 2017-18, which had emanated from an assessment order under Section 147. The case centrally engaged the procedural validity of the reassessment chain, including whether the requirements of Section 148A(d), the limitation provisions of Section 149, and the sanction requirements under Sections 151(i) and 151(ii) had been complied with.

4. MS Khurana Engineering Limited vs Assistant Commissioner of Income Tax on 8 April, 2026

Bench: Gujarat High Court
Date: 08 April 2026
Sections engaged: 132, 132A, 148, 149, 152(3), 153A, 153C, 9
Procedural / substantive ground: This Special Civil Application before the Gujarat High Court challenged reassessment proceedings initiated under Section 148 in a case also involving search-related provisions under Sections 153A and 153C. The engagement of Section 149 indicates that limitation for issuance of the notice was in issue, and Section 152(3) concerning the effect of certain orders was also cited.

5. West India Infratech Private Limited vs Assistant Commissioner of Income Tax on 8 April, 2026

Bench: Gujarat High Court
Date: 08 April 2026
Sections engaged: 132, 132A, 148, 149, 152(3), 153A, 153C, 36
Procedural / substantive ground: Filed as a separate Special Civil Application before the Gujarat High Court on the same date as the Khurana Engineering matter, this petition similarly engaged the intersection of Section 148 reassessment with search and requisition provisions under Sections 132, 132A, 153A, and 153C. Limitation under Section 149 and the scope of Section 152(3) were also cited, suggesting parallel questions of law were raised across both Gujarat petitions decided on 08 April 2026.

6. Agricultural Produce Marketing Committee, Gundlupet vs Income Tax Officer, Ward-1, Chamarajanagar on 7 April, 2026

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 07 April 2026
Sections engaged: 1, 10, 144, 147, 148, 148A(d), 151, 44, 6
Procedural / substantive ground: The Agricultural Produce Marketing Committee filed four appeals before the Bangalore Bench covering Assessment Years 2015-16, 2016-17, 2018-19, and 2019-20, all arising from reassessment proceedings. The case engaged the procedural requirements under Section 148A(d) and the sanction requirement under Section 151, alongside the substantive question of exemption under Section 10, and assessment under Section 144 in the reopened proceedings.

7. Sivana Realty Private Limited vs Deputy Commissioner of Income Tax on 6 April, 2026

Bench: Bombay High Court
Date: 06 April 2026
Sections engaged: 148, 148A(d), 271(1)(c), 274, 31, 31(1)
Procedural / substantive ground: This writ petition before the Bombay High Court was filed as Writ Petition (L) No. 41243 of 2025, challenging proceedings that engaged both Section 148 reassessment and penalty provisions under Sections 271(1)(c) and 274. The citation of Section 148A(d) indicates that the validity of the pre-notice inquiry and satisfaction order was in contest, alongside the propriety of penalty proceedings initiated in conjunction with the reopened assessment.

8. Sunil Kumar Sahoo vs Deputy Commissioner of Income Tax on 31 March, 2026

Bench: Orissa High Court
Date: 31 March 2026
Sections engaged: 142, 143, 143(1), 144, 147, 148, 156, 22, 271C, 282, 47, 69A
Procedural / substantive ground: Filed as a writ petition under Articles 226 and 227 of the Constitution before the Orissa High Court, this matter engaged a broad procedural landscape including assessment under Section 144, demand notice under Section 156, service under Section 282, and treatment of unexplained money under Section 69A. The engagement of Section 148 alongside Sections 142 and 143 suggests that questions of procedural sequence and validity of assessment and reassessment steps were central to the petition.

9. Sachin Mohanlal Chordia, Pune vs Income Tax Officer Ward 5(1), Pune on 30 March, 2026

Bench: Income Tax Appellate Tribunal - Pune
Date: 30 March 2026
Sections engaged: 11, 139, 147, 148, 148A, 149, 151, 151(i), 250, 3(1), 4, 50
Procedural / substantive ground: Two appeals were filed by the assessee before the Pune Bench for Assessment Years 2016-17 and 2017-18, both arising from separate assessment orders under Section 147, challenged before the NFAC CIT(A) under Section 250. The procedural validity of the reassessment, including compliance with Section 148A, the limitation provisions of Section 149, and the sanction requirement under Section 151(i), was engaged across both years.

10. Hitech Poultry Feeds, Puttur vs Income Tax Officer, Puttur on 30 March, 2026

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 30 March 2026
Sections engaged: 10, 142(1), 144, 148, 148A, 250, 271B, 272A(1), 272A(1)(d), 273B, 275
Procedural / substantive ground: This appeal before the Bangalore Bench for Assessment Year 2018-19 challenged an NFAC order dated 23 June 2025, arising from a reassessment initiated under Section 148 and assessed under Section 144. The engagement of Sections 271B, 272A(1)(d), 273B, and 275 indicates that penalty proceedings — including penalties for failure to get accounts audited and failure to comply with notices — were adjudicated alongside the validity of the reassessment initiated under Section 148A.

11. DCIT CC 5/2, Mumbai vs Kalyan Vyapaar Private Limited, Mumbai on 27 March, 2026

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 27 March 2026
Sections engaged: 1, 143(3), 148, 14A, 3, 32, 5, 51, 68, 8
Procedural / substantive ground: The Revenue filed three appeals before the Mumbai Bench covering Assessment Years 2011-12, 2013-14, and 2015-16. The case engaged reassessment under Section 148 read with assessment under Section 143(3), alongside substantive issues concerning unexplained cash credits under Section 68, disallowance under Section 14A, and depreciation under Section 32.

12. Late Shri Basapur Ningappa vs Income Tax Officer on 27 March, 2026

Bench: Karnataka High Court
Date: 27 March 2026
Sections engaged: 147, 148, 148A, 270A, 272A(1)(d)
Procedural / substantive ground: This writ petition before the Karnataka High Court was filed by the legal representatives of the deceased assessee. The matter engaged the validity of proceedings under Sections 147 and 148 read with the procedural requirements of Section 148A, alongside penalty provisions under Section 270A and Section 272A(1)(d). The involvement of legal representatives suggests that the maintainability or continuation of reassessment proceedings against a deceased assessee may have been in issue.

Patterns across these 12 rulings

Procedural prerequisites under Sections 148A and 151 are a recurring battleground. At least five of the twelve cases — Somnath Kannure, Agricultural Produce Marketing Committee, Sivana Realty, Sachin Mohanlal Chordia, and Late Shri Basapur Ningappa — specifically cite Section 148A (including Section 148A(d)) and/or Section 151, reflecting sustained litigation around whether the mandatory pre-notice inquiry and prior-sanction requirements have been fulfilled before a reassessment notice is issued.
Limitation under Section 149 is frequently litigated alongside Section 148. Four cases — Somnath Kannure, MS Khurana Engineering, West India Infratech, and Sachin Mohanlal Chordia — cite both Section 148 and Section 149 together, indicating that challenges to the time-bar on issuing reassessment notices remain a common ground of contest before both the ITAT and High Courts.
Search-triggered reassessments generate a distinct cluster of issues. The two Gujarat High Court petitions (MS Khurana Engineering and West India Infratech) and the Chandigarh ITAT case (Torque Pharmaceuticals) each involve reassessments arising from or connected to search and requisition proceedings under Sections 132 and 132A, with additional provisions such as Sections 153A, 153C, and 148B engaged, reflecting the layered procedural framework applicable to post-search reassessments.
Penalty provisions are frequently adjudicated in tandem with reassessment validity. Cases including Sivana Realty (Sections 271(1)(c) and 274), Hitech Poultry Feeds (Sections 271B, 272A(1)(d), 273B, and 275), and Late Shri Basapur Ningappa (Sections 270A and 272A(1)(d)) demonstrate that challenges to Section 148 notices often proceed together with challenges to penalty orders issued consequent to the reopened assessments, requiring courts and tribunals to address both streams simultaneously.
Multiple assessment years are routinely consolidated in reassessment appeals. The Agricultural Produce Marketing Committee appeal covered four assessment years (2015-16, 2016-17, 2018-19, and 2019-20), Sachin Mohanlal Chordia covered two years (2016-17 and 2017-18), and DCIT Mumbai vs Kalyan Vyapaar covered three years (2011-12, 2013-14, and 2015-16), suggesting that when reassessment notices are challenged, taxpayers and revenue alike tend to contest all affected years in consolidated proceedings.

How to use this compilation

This compilation is organised as a first-pass research index. Each entry identifies the forum, date, sections engaged, and a summary of the procedural or substantive ground drawn from available source data. Researchers should treat these entries as pointers to the full judgment text rather than as self-contained statements of law. Before relying on any ruling in practice, the full order should be retrieved from the relevant court portal or an authenticated legal database, read in its entirety, and checked for any subsequent stay, reversal, or modification by a higher forum.

Given the pace of litigation around reassessment provisions — particularly following legislative amendments to Sections 147 through 151 — researchers should verify whether any ruling in this compilation has been considered, distinguished, or overruled in subsequent decisions. It is also advisable to cross-reference applicable CBDT circulars, instructions, and Finance Act amendments that may bear on the interpretation of Section 148 and related provisions for the relevant assessment year, since the procedural framework applicable to notices issued before and after the Finance Act 2021 amendments differs materially.

Finally, this compilation does not claim to be exhaustive of all Section 148 litigation during the covered period. The cases indexed here represent a sample drawn from the TaxNoticeAI structured legal corpus. Researchers working on specific fact patterns should conduct independent searches across official court portals and authenticated legal databases to ensure completeness of their case law review.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 148 Reassessment: 12 ITAT & High Court Rulings (2026)