This compilation indexes twelve income-tax rulings — three from the Gujarat High Court and nine from the Income Tax Appellate Tribunal (ITAT benches at Hyderabad, Delhi, Ahmedabad, Bangalore, and Mumbai) — all pronounced between 10 June 2026 and 16 June 2026. Each ruling engages Section 148A(b) of the Income Tax Act, 1961, which governs the mandatory show-cause notice step that must precede any order to reopen an assessment under Section 148A(d). The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured, forum-tagged reference to recent judicial activity on reassessment procedure. All entries are drawn from the TaxNoticeAI structured legal corpus; no editorial opinion on the correctness of any ruling is expressed.

Research index only — not legal or tax advice. This page summarises publicly available judgments for reference purposes. Readers must verify facts and outcomes against the full text of each judgment and consult qualified advisers before taking any action.

The statutory framework in one paragraph

Section 148A of the Income Tax Act, 1961 was inserted by the Finance Act, 2021 with effect from 1 April 2021 and establishes a pre-notice inquiry-and-hearing mechanism before a reassessment notice under Section 148 can be issued. Section 148A(b) specifically requires the Assessing Officer to serve on the assessee a show-cause notice, along with the information and material relied upon, and to afford the assessee an opportunity of being heard — generally not less than seven days and not more than thirty days — before passing the order contemplated under Section 148A(d). The Section 148A(d) order, which decides whether it is a fit case for issuance of a Section 148 notice, must be passed after considering the assessee's reply (if any) to the Section 148A(b) notice. This pre-notice procedural chain — information → Section 148A(b) show-cause → Section 148A(d) order → Section 148 notice — has generated significant litigation on issues of limitation (Section 149), sanction (Section 151), adequacy of notice period, and application of mind by the Assessing Officer.

The 12 rulings

1. Gordhanbhai Devjibhai Kapadia vs Income Tax Officer, Ward 1(2)(1)

Bench: Gujarat High Court
Date: 16 June 2026
Sections engaged: 148, 148A(b), 148A(d), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition, filed as Special Civil Application No. 9146 of 2023, challenged the notice issued under Section 148 dated 27.07.2022 and the order under Section 148A(d) dated 26.07.2022, relating to Assessment Year 2013-2014. Per the source preview, the Assessing Officer had originally issued a notice dated 04.06.2021 under Section 148 for AY 2013-2014 during the extended time period under the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020. The appeal was heard and decided as an oral order by the Gujarat High Court on 16 June 2026.

2. Bhavna Chimanlal Udernani vs Office Of Income Tax Officer, Ward

Bench: Gujarat High Court
Date: 15 June 2026
Sections engaged: 147, 148, 148A(b), 148A(d), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This oral judgment, pronounced in Special Civil Application No. 6940 of 2023, involved multiple consolidated SCAs spanning Assessment Years 2013–14, 2014–15, 2016–17, and 2017–18. The source preview contains a tabular summary recording, for each SCA, the date of the Section 148 notice issued under TOLA, the number of surviving days available till 30.06.2021, and the date of providing information under Section 148A(b). The Gujarat High Court approved this judgment for reporting, indicating that it was considered of precedential significance with respect to the TOLA-based limitation and the Section 148A(b) notice timelines.

3. M/S Touch Comm Tech Private Limited vs National E-Assessment Centre, Delhi

Bench: Gujarat High Court
Date: 15 June 2026
Sections engaged: 132, 143(3), 147, 148, 148A(b), 148A(d), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Special Civil Application No. 16693 of 2024, the petitioner sought quashing and setting aside of the order dated 27.07.2022 passed under Section 148A(d) reopening the assessment for Assessment Year 2013-14. Per the source preview, the petitioner's counsel submitted at the outset that the reopening was required to be quashed on the ground of non-application of mind by the respondent on the credit entries mentioned in the Return of Income. The Gujarat High Court approved this judgment for reporting, reflecting the court's view that it addressed a question of wider significance regarding the adequacy of the Section 148A(d) order.

4. Mallareddy Donthi,Karimnagar vs ITO, Ward - 2, Karimnagar

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 12 June 2026
Sections engaged: 142(1), 147, 148, 148A, 148A(b), 148A(d), 149(1), 149(1)(b), 151, 163
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA No. 727/Hyd/2026 for Assessment Year 2015-16 (PAN: BLEPD7595K) was filed by the assessee against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi dated 05/01/2026, which in turn arose from the order passed by the Assessing Officer. The source preview indicates that the assessee was not represented before the Tribunal while the Department was represented by Shri Vamshi Krishna, Sr-AR; the appeal was heard on 08.06.2026 and pronounced on 12.06.2026. Multiple sections relating to the validity and limitation of reassessment proceedings — including Section 149(1)(b) and Section 151 — were engaged in this matter.

5. Madhavi Kompally,Hyderabad vs ITO, Ward- 9(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 12 June 2026
Sections engaged: 147, 148, 148A, 148A(b), 148A(d), 149(1), 149(1)(b), 151, 163, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA No. 2427/Hyd/2025 for Assessment Year 2015-16 (PAN: CMJPK9319R) was filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi. The source preview confirms the appeal was heard on 08.06.2026 and pronounced on 12.06.2026 before the Hyderabad SMC Bench. The sections engaged include Section 69A alongside the full reassessment chain, suggesting that the substantive additions — in addition to the procedural validity of the reassessment — were in issue before the Tribunal.

6. Vijay Kumar Soni,Delhi vs ITO Ward 47(1), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 12 June 2026
Sections engaged: 144B, 147, 148, 148A(b), 148A(d), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA No. 5459/Del/2025 for Assessment Year 2014-15 (PAN: AABPS4209A) raised as its first issue the CIT(A)'s confirmation of the Assessing Officer's assumption of jurisdiction under Section 147 read with Section 148A(d) and the issuance of a notice under Section 148 dated 29 June 2022. Per the source preview, the assessee is an individual, and the Assessing Officer's information related to commodity trading on NSEL, where brokers had portrayed the trades as investment products offering 12% to 14% assured returns; after suspension of trading, NSEL did not fulfil payment obligations to clients. The matter was heard on 04.06.2026 and pronounced on 12.06.2026 before Delhi Bench-F.

7. Mahesh Upendra Majithia,Ahmedabad vs DCIT Circle 2 1 1 , Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 12 June 2026
Sections engaged: 148, 148A(b), 148A(d), 149(1)(a), 149(1)(b), 151, 282A, 80G
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA No. 620/Ahd/2026 for Assessment Year 2019-20 (PAN: AFTPM3502P) raised two prominent procedural challenges per the source preview. First, the assessee contended that the Assessing Officer erred in invoking Section 149(1)(b) despite the alleged escapement not exceeding Rs. 50,00,000, which is the threshold required for reassessment of matters beyond three years from the end of AY 2019-20. Second, the assessee argued that the AO erred by relying on an unsigned approval under Section 151, alleged to be in violation of Section 282A and the DSC Policy, 2018, with the submission that the absence of valid sanction renders the reassessment proceedings void.

8. Kassia Credit Co-Operative Society vs DCIT, Circle-3(1)(1), Bangalore

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 11 June 2026
Sections engaged: 139(1), 147, 148, 148A(b), 148A(d), 80, 80A, 80P
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA No. 84/Bang/2026 for Assessment Year 2018-19 (PAN: AACAK7304A) was filed against the CIT(A) NFAC order dated 13.11.2025, arising from an assessment order passed under Section 147 dated 23.03.2023. The source preview notes that the assessee — a credit co-operative society — had not filed its return of income under Section 139(1), and that the grounds of appeal included a challenge to the disallowance of a deduction of Rs. 83,89,567 claimed under Section 80P. The co-existence of the reassessment challenge and the Section 80P deduction dispute reflects that both jurisdictional and substantive issues were raised before the Bangalore Bench.

9. Popular Buffer Investments Private vs Income Tax Officer Ward 7(3)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 10 June 2026
Sections engaged: 144, 144B, 147, 148, 148A(b), 148A(d), 149, 250
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA No. 1298/Mum/2026 for Assessment Year 2015-16 (PAN: AAGCP8196H) was directed against the CIT(A) NFAC order dated 29.09.2025 passed under Section 250. Per the source preview, the substantive assessment order dated 30.12.2023 was passed by the National Faceless Assessment Centre under Section 147 read with Section 144 of the Act. The appeal was heard on 11.05.2026 and pronounced on 10.06.2026 before Mumbai "C" Bench, with both the reassessment jurisdiction and the faceless assessment procedure being in issue.

10. Mr. Rahul Vijay Rai ,Mumbai vs ITO (Int Tax ) Ward 4(1)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 10 June 2026
Sections engaged: 144C(1), 144C(13), 147, 148, 148A(b), 148A(d), 68, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA No. 6527/Mum/2025 for Assessment Year 2016-17 (PAN: ANYPR0495B) involved an assessee described as a seafarer and non-resident Indian for past several years who did not file any return of income for the year under dispute. Per the source preview, the Assessing Officer, on the basis of information available in the ITBA/Insight Portal, found that during the year the assessee had entered into financial transactions of Rs. 1,70,40,005 — comprising purchase of an immovable property of Rs. 1,36,86,550 and deposits of cash in bank accounts — and initiated reassessment proceedings accordingly. The appeal was heard on 21.04.2026 and pronounced on 10.06.2026 before Mumbai "I" Bench.

11. Ask Corporation,Andheri West vs ITO 24(1)(1), Piramal Chamber

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 10 June 2026
Sections engaged: 147, 148, 148A(b), 148A(d), 151(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: I.T.A. No. 2638/Mum/2026 for Assessment Year 2017-18 (PAN: AAMFA4763G) was filed against the CIT(A) NFAC order dated 13.01.2026, arising from the assessment order under Section 147 dated 15.05.2023. The source preview indicates that an additional ground (Ground No. 11) was filed by the assessee on 05.05.2026, and that Section 151(ii) — which concerns the specific category of sanctioning authority required for reassessment — was a section specifically engaged in this appeal. The matter was heard on 14.05.2026 and pronounced on 10.06.2026 before Mumbai "SMC" Bench.

12. Sajjapuram Primary Agricultural Co vs ITO, Ward-1, Ongole

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 10 June 2026
Sections engaged: 148, 148A(b), 148A(d), 149, 151
Outcome: Outcome not specified in source
Procedural / substantive ground: ITA Nos. 2461 & 2462/Hyd/2025 covered two Assessment Years — 2018-2019 and 2019-2020 (PAN: AAHAS0325A) — for a primary agricultural cooperative credit society based in Prakasam District, Andhra Pradesh. Per the source preview, the assessee filed a petition for admission of additional grounds, and the learned Authorised Representative relied upon a Telangana High Court decision reported at [2023] 156 taxmann.com 178 in support of the assessee's position. The appeal was heard on 03.06.2026 and pronounced on 10.06.2026 before the Hyderabad "A-SMC" Bench, with both Section 149 limitation and Section 151 sanction in issue.

Patterns across these 12 rulings

TOLA-era reassessments remain heavily litigated. Multiple cases in this compilation — including Case 1 (AY 2013-14, notice dated 04.06.2021) and Case 2 (spanning AY 2013-14 through 2017-18, with notices dated in June 2021) — directly involve reassessment notices issued during or immediately following the TOLA extension window. Courts and tribunals continue to be called upon to scrutinise whether the TOLA-extended limitation periods and the Section 148A(b) procedural requirements were correctly applied.
Section 151 sanction validity is a recurring ground. At least two cases in this set — Case 7 (Mahesh Upendra Majithia, where an unsigned approval under Section 151 in alleged violation of Section 282A and the DSC Policy, 2018 was challenged) and Case 11 (Ask Corporation, where Section 151(ii) specifically appears in the sections engaged) — show that the adequacy and authenticity of the mandatory prior sanction for reassessment is a live and recurring issue across ITAT benches.
Section 149 limitation thresholds are frequently contested. Cases 4, 5, 7, 9, and 12 all engage Section 149, and in Case 7 the assessee's ground specifically contended that the alleged escapement did not exceed the Rs. 50,00,000 threshold required to invoke Section 149(1)(b) for periods beyond three years. This threshold-based limitation argument appears to be a standard ground raised wherever reassessments are initiated for older assessment years under the post-amendment framework.
Non-application of mind by the Assessing Officer is a substantive challenge at the High Court level. Case 3 (M/S Touch Comm Tech Private Limited) illustrates that Gujarat High Court petitions under the post-amendment Section 148A framework are being framed around the allegation that the Assessing Officer failed to apply mind to material already on record — such as credit entries in the Return of Income — before passing the Section 148A(d) order. This is distinct from a pure limitation challenge and goes to the quality of the jurisdictional order itself.
Multi-forum, multi-AY consolidation is common. Case 2 (Bhavna Chimanlal Udernani) consolidated four separate SCAs covering four Assessment Years in a single judgment, and Case 12 (Sajjapuram Primary Agricultural Co) consolidated two ITAs for two consecutive Assessment Years. This pattern suggests that reassessment challenges arising from the same round of departmental action — often TOLA-era notices — are being heard together, and that researchers should check for companion matters when reviewing any single ruling.

How to use this compilation

This index is a starting point for targeted judgment retrieval, not a substitute for reading the full text of each ruling. Because all twelve source previews in this compilation are truncated — several end mid-sentence or contain only the cause title, bench composition, and opening procedural paragraphs — the dispositive findings, ratio decidendi, and operative directions are not captured here. Before relying on any ruling for any purpose, researchers should retrieve the full judgment text from indiankanoon.org, the official ITAT portal, or the relevant High Court's case-status system, and confirm that the outcome has not been appealed, stayed, or reversed by a higher forum.

Researchers should also cross-check the sections engaged against CBDT circulars, instructions, and Finance Act amendments that may have been issued after the date of the relevant ruling. The reassessment framework under Sections 147, 148, 148A, and 149 has been the subject of multiple Finance Act amendments, CBDT instructions on TOLA applicability, and Supreme Court pronouncements — any of which could affect the precedential weight of a ruling cited here. Parallel developments in faceless assessment procedure (relevant to several cases in this set that involve the National Faceless Assessment Centre and National Faceless Appeal Centre) should similarly be checked against current CBDT guidelines.

Finally, because outcomes for all twelve cases are recorded as "Outcome not specified in source," researchers must independently verify whether each appeal was allowed, dismissed, remanded, or disposed of on preliminary grounds before drawing any inference about the current judicial trend on any specific point of law.

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 148A(b) Show-Cause Notices: 12 Recent ITAT and HC Rulings (2026)