This compilation indexes twelve rulings — ten from High Courts (Gujarat, Madras, Karnataka, Delhi, and Bombay) and two from the Income Tax Appellate Tribunal (Bangalore and Cuttack Benches) — that engage Section 148A(d) of the Income Tax Act, 1961. All orders are dated between March and June 2026. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who track judicial activity on the statutory reassessment framework introduced by the Finance Act, 2021. Each entry below sets out the bench, date, sections engaged, outcome direction, and a brief procedural or substantive note drawn strictly from the source preview for that case.

Research index only. This page is a structured case-law reference, not legal or tax advice. Readers should verify every ruling against the full judgment text and check for any subsequent stays, appeals, or reversals before relying on it in any professional capacity.

The statutory framework in one paragraph

Section 148A of the Income Tax Act, 1961 — inserted by the Finance Act, 2021 with effect from 1 April 2021 — prescribes a mandatory pre-notice procedure that the Assessing Officer must follow before issuing a notice for reassessment under Section 148. Clause (d) of Section 148A specifically requires the Assessing Officer to pass a speaking order, after providing the assessee an opportunity to be heard under Section 148A(b) and after considering the reply furnished, deciding whether or not the case is a fit one for issuance of a notice under Section 148. This order under Section 148A(d) is a jurisdictional precondition; a notice under Section 148 can be issued only after such an order is validly passed. The requirement is read alongside the time-limit provisions in Section 149 and the sanction requirements in Section 151, and its interplay with the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA) has generated substantial litigation across High Courts and the ITAT.

The 12 rulings

1. Hina Prakash Shah vs The Income Tax Officer, Ward 1(3)(1)

Bench: Gujarat High Court
Date: 9 June 2026
Sections engaged: 147, 148, 148A(b), 148A(d), 3(1), 30
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (R/Special Civil Application No. 6480 of 2023) was filed before the Gujarat High Court at Ahmedabad challenging notices and orders issued under the reassessment framework across multiple assessment years and SCA numbers. The source preview contains a tabular record of SCA-wise data tracking the date of notice under Section 148, the number of surviving days of time available under TOLA as on 30.06.2021, and the date of providing information under Section 148A(b), indicating that the challenge centres on the validity and timeliness of the pre-notice procedure under Sections 148A(b) and 148A(d) as applied across those assessment years.

2. Shanmugha Arts And Science Technology vs ACIT (Exemptions)

Bench: Madras High Court
Date: 3 June 2026
Sections engaged: 143(3), 147, 148, 148A, 148A(b), 148A(d), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 29752 of 2023, reserved on 24.02.2026 and pronounced on 03.06.2026) was filed under Article 226 of the Constitution of India seeking a Writ of Certiorarified Mandamus to call for and quash the order dated 02.05.2022 bearing DIN & Notice No. ITBA/AST/F/148A/2022-23/1042929205(1), passed under Section 148A(d) for PAN AAAAB0187C for Assessment Year 2015-16, and all proceedings flowing from it. The petition also engages Section 149(1)(b), suggesting that the time-limit for reopening was a ground of challenge in the proceedings.

3. Deccan Creations Private Limited vs ACIT, Circle-2(2)(1), Bangalore

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 27 April 2026
Sections engaged: 148, 148A(d), 151
Outcome: Outcome not specified in source
Procedural / substantive ground: In ITA No. 2575/Bang/2025 for Assessment Year 2016-17, the ITAT Bangalore Bench examined the interplay between the sanction requirements under Section 151 and the order-passing obligation under Section 148A(d). The source preview reproduces a comparative table of the specified authorities required to sanction reassessment under the old and new regimes of Section 151, alongside a reference to Section 148A(d) as the provision requiring the Assessing Officer to pass an order deciding whether or not the case is fit for issuance of a notice under Section 148, indicating that the validity of sanction and the Section 148A(d) order were both in issue before the Tribunal.

4. M/S. Nandi Design Group vs Assessment Unit

Bench: Karnataka High Court
Date: 23 April 2026
Sections engaged: 148A(b), 148A(d), 147
Outcome: Outcome not specified in source
Procedural / substantive ground: Writ Petition No. 12447 of 2026 (T-IT) was filed before the Karnataka High Court at Bengaluru under Articles 226 and 227 of the Constitution of India, praying to quash the assessment order dated 31.12.2023 passed under Section 147 read with Sections 144 and 144B for Assessment Year 2019-20. The petitioner, a partnership firm with PAN AAGFN3390L, challenged proceedings that arose out of the pre-notice process under Sections 148A(b) and 148A(d), with the Section 147 assessment order being the ultimate target of the writ.

5. Shri Yandunandan Petroleum Through Its vs Income Tax Officer Ward 1

Bench: Gujarat High Court
Date: 16 April 2026
Sections engaged: 148, 148A(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: R/Special Civil Application No. 4824 of 2026 was filed before the Gujarat High Court at Ahmedabad and was approved for reporting. The source preview contains a tabular record tracking, across multiple SCA numbers, the dates of notices under Section 148 and related procedural milestones, and the oral judgment was delivered on 16.04.2026. The appeal was filed challenging the notice and the proceedings connected with the Section 148A(d) order, per the source preview.

6. Abhinav Jain vs Income Tax Officer & Ors

Bench: Delhi High Court
Date: 13 April 2026
Sections engaged: 148A(b), 148A(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: W.P.(C) 2638/2023 was reserved on 15.12.2025 and judgment was delivered on 13.04.2026 by the Delhi High Court. The petition relates to Assessment Year 2018-19, and the source preview records that the petitioner maintained bank accounts including NRE No. 015013110007312 with Bank of India, New Delhi and Savings Account No. 0650000100137681 with Punjab National Bank, New Delhi, and that for AY 2018-19 certain verification queries were generated on the Insight Portal of the Income Tax Department on account of the petitioner not filing his tax returns, in response to which on 05.02.2019 the petitioner filed his e-response. The challenge before the court engaged Sections 148A(b) and 148A(d).

7. Mansukh Pitamberbhai Kasundra vs Income Tax Officer Ward 1

Bench: Gujarat High Court
Date: 8 April 2026
Sections engaged: 148, 148A(b), 148A(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: R/Special Civil Application No. 4672 of 2026 was filed before the Gujarat High Court at Ahmedabad under Article 226 of the Constitution of India, challenging the notice under Section 148 dated 12.07.2022. The source preview contains a tabular record tracking multiple SCA numbers with the dates of notices under Section 148 and related procedural milestones including dates of orders under Section 148A(d), mirroring the format seen in related Gujarat High Court petitions filed around the same period.

8. Sivana Realty Private Limited vs Deputy Commissioner Of Income Tax

Bench: Bombay High Court
Date: 6 April 2026
Sections engaged: 31, 148A(d), 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: Writ Petition (L) No. 41243 of 2025 was filed before the Bombay High Court under Article 226 of the Constitution of India, impugning various assessment orders, demand notices, reassessment proceedings, and penalty proceedings initiated under the Income Tax Act, 1961 in respect of assessment years pertaining to the period prior to 19 July 2023, being the date on which the Resolution Plan in respect of the petitioner came to be approved by the National Company Law Tribunal, Mumbai Bench under Section 31 of the Insolvency and Bankruptcy Code. The Section 148A(d) reassessment proceedings are among the impugned actions, alongside penalty proceedings, with the approval of the Resolution Plan forming the central factual premise of the challenge.

9. Mrs. Manjubala Pradhan, Sundergarh vs ITO, Ward-1, Rourkela

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 26 March 2026
Sections engaged: 148, 151, 148A(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: In I.T.A. No. 64/CTK/2026 for Assessment Year 2016-17, the appellant (PAN: ALRPP7009C) submitted before the ITAT Cuttack Bench that the notice under Section 148 was issued on 30.08.2022 and that it had been issued beyond the three-year period from the end of the relevant assessment year. The source preview records these submissions and indicates that the validity of the Section 148 notice — and by extension the Section 148A(d) order that preceded it — was the central issue before the Tribunal, with Section 151 sanction requirements also engaged.

10. Rameshchandra Ratilal Bordiwala, Lhs vs The Income Tax Officer, Ward 1(2)(1)

Bench: Gujarat High Court
Date: 23 March 2026
Sections engaged: 148A(d), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: R/Special Civil Application No. 9019 of 2023 was filed before the Gujarat High Court at Ahmedabad under Article 226 of the Constitution of India, challenging the order under Section 148A(d) dated 20.07.2022, the notice under Section 148 dated 21.07.2022, and the consequential reassessment proceedings, on the ground that the notice would be invalid and time-barred. The petition was heard and the oral judgment delivered on 23.03.2026 by the bench constituted for the purpose.

11. Ajay Jaysukhlal Mehta vs Income Tax Officer, Ward 5(3)(1)

Bench: Gujarat High Court
Date: 23 March 2026
Sections engaged: 148, 148A(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: R/Special Civil Application No. 8435 of 2023 was filed before the Gujarat High Court at Ahmedabad under Article 226 of the Constitution of India, challenging the notice under Section 148 dated 26.07.2022 on the ground that the notice would be invalid and time-barred. The source preview records that the Assessing Officer issued a notice dated 30.06.2021 under Section 148 for Assessment Year 2013-2014 during the extended period, and the oral order was pronounced on 23.03.2026.

12. Gowthaman S vs Income Tax Officer, Ward 2

Bench: Madras High Court
Date: 23 March 2026
Sections engaged: 159, 148A(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: W.A. No. 529 of 2026 is a writ appeal filed before the Madras High Court under Clause 15 of the Letters Patent, seeking to set aside the order dated 27.10.2025 passed by the learned Single Judge in W.P. No. 39793 of 2025. The appellant, described as the legal heir of Late K. Selvarasu, had by way of the writ petition challenged the order dated 31.03.2024 passed under Section 148A(d) of the Income Tax Act, 1961 and the assessment order dated thereafter, making this a notable instance of the Section 159 (legal representative) framework being engaged alongside a Section 148A(d) challenge at the appellate stage.

Patterns across these 12 rulings

Time-bar and TOLA as a recurring flashpoint. Across several of the Gujarat High Court petitions (cases 1, 5, 7, 10, and 11), the source previews consistently record tabular data tracking the number of surviving days of time available under TOLA as on 30.06.2021 and the dates of notices and orders under Sections 148A(b), 148A(d), and 148. This suggests that the validity of reassessment proceedings in the context of TOLA-extended limitation periods is a dominant challenge theme across these rulings.
Multi-forum character of Section 148A(d) litigation. The twelve rulings span five High Courts (Gujarat, Madras, Karnataka, Delhi, and Bombay) and two ITAT Benches (Bangalore and Cuttack), confirming that challenges to Section 148A(d) orders are being pressed simultaneously at the writ stage in High Courts and by way of statutory appeals before the ITAT, with no single forum emerging as the exclusive venue.
Section 151 sanction requirements litigated alongside Section 148A(d). Cases 3 and 9 (ITAT Bangalore and ITAT Cuttack respectively) both engage Section 151, which governs the authority required to sanction reassessment, alongside Section 148A(d). The Bangalore ruling's source preview explicitly reproduces a table comparing the specified authorities under the old and new regimes, indicating that the adequacy of sanction is being raised as a separate — or concurrent — ground to the Section 148A(d) challenge.
IBC Resolution Plan as an intersecting ground. Case 8 (Sivana Realty, Bombay High Court) presents a distinct factual pattern in which the approval of a Resolution Plan under Section 31 of the Insolvency and Bankruptcy Code is pleaded as a basis for impugning reassessment and penalty proceedings that predate the plan's approval. This IBC-income tax intersection, while a minority pattern in this set, represents a structurally different challenge to Section 148A(d) proceedings compared to pure limitation-based challenges.
Legal heir standing under Section 159. Case 12 (Gowthaman S, Madras High Court) is the only ruling in this set where the appellant appears as the legal heir of a deceased assessee, invoking Section 159 alongside Section 148A(d). The writ appeal posture (Letters Patent appeal against a Single Judge's dismissal) also distinguishes it procedurally from the first-instance writ petitions that constitute the majority of this compilation.

How to use this compilation

This compilation functions as a first-pass research index. Each entry identifies the forum, the date of the order, the sections in play, and the procedural posture of the case as disclosed by the source preview. Researchers should treat every entry as a pointer to the full judgment text rather than a self-contained summary: the source previews reproduced in this database capture the opening portions of the orders and do not always contain the dispositif or the substantive reasoning that follows. Before citing any ruling in a memorandum, opinion, or filing, the full text of the judgment should be retrieved from the relevant court portal (indiankanoon.org, the High Court's official judis portal, or the ITAT's official website) and read in its entirety.

Researchers should also check, for each ruling, whether a stay has been granted by a higher court, whether a further appeal is pending (for instance, a Letters Patent or division bench appeal against a Single Judge order, or a Supreme Court special leave petition against a High Court division bench order), and whether the ruling has been distinguished, followed, or overruled in any subsequent judgment. The legal landscape around Section 148A(d) — particularly its interaction with TOLA, Section 149, and Section 151 — continues to evolve rapidly, and a ruling indexed here may have been overtaken by a subsequent High Court or Supreme Court pronouncement by the time a researcher consults this page.

Finally, researchers working on matters that involve parallel CBDT instructions, circulars, or standard operating procedures on the reassessment process should cross-check this case-law index against the current CBDT circular repository, as administrative instructions on the operation of Sections 148 and 148A are updated periodically and may bear on the interpretation adopted in a given ruling.

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(d) Reassessment Orders: 12 HC and ITAT Rulings (2026)