Section 148A of the Income-tax Act, 1961, inserted by the Finance Act 2021 and re-cast by the Finance (No.2) Act 2024, is one of the most heavily litigated provisions in the post-2021 reassessment regime. Across the last 24 months, ITAT benches and High Courts have repeatedly quashed Section 148A(d) orders and consequential Section 148 notices for procedural defects — most commonly absence of a valid Section 151 sanction, denial of a meaningful hearing under Section 148A(b), or jurisdictional missteps after the Faceless Assessment Scheme.

This compilation lists 11 such rulings from our case-law corpus, with the cited sections, the bench, and the procedural ground on which each notice was set aside. It is intended as a research starting point for in-house tax teams, Big-4 associates, and law firm researchers building a brief.

What this page is. A structured index of primary-source case data (case name, court, date, sections cited, outcome where reported). It is not legal advice. Where the holding is paraphrased, the source court's reasoning is summarised — verify against the full judgment before citing in any pleading.

The statutory framework in one paragraph

Section 148A requires the Assessing Officer, before issuing a notice under Section 148, to (a) conduct an inquiry if necessary with prior approval of the specified authority under Section 151, (b) furnish the assessee with a show-cause notice and the information relied upon, (c) consider the reply, and (d) pass a speaking order under Section 148A(d) recording reasons. The Supreme Court in Union of India v. Ashish Agarwal (2022) 444 ITR 1 read these requirements as mandatory and as a condition precedent to a valid Section 148 notice. Where any limb is missed — particularly the Section 151 sanction or the 148A(b) hearing — the notice is liable to be quashed on jurisdictional grounds.

The 11 rulings

1. Sunil Chablani v. Circle (Intl Tax), Jaipur

Bench: Income Tax Appellate Tribunal, Jaipur
Date: 22 July 2024
Sections engaged: 115B, 142(1), 144, 144C, 144C(5), 147, 148, 148A, 151A, 234A, 45, 48, 54, 69, 69A, 71
Outcome: Taxpayer succeeded
Procedural ground: The ITAT relied on prior decisions and quashed the assessment order passed under Section 148A(d) on the ground that no valid notice had been issued under Section 148, and the Section 151 sanction requirement (read with 151A — Faceless Reassessment Scheme) was violated. The bench treated the absence of a valid 148 notice as going to the root of jurisdiction.

2. Sri Amritlal Nitesh Kumar v. Assessment Unit

Bench: Karnataka High Court
Date: 11 December 2025
Sections engaged: 144B, 147, 148, 148A(b), 148A(d), 151A, 156, 2, 270A, 271A, 272A(1)(d)
Procedural ground: The petition challenged the 148A(d) order and consequential 148 notice; the bench tested the proceeding against the Faceless Assessment Scheme requirements under 144B and 151A.

3. M/S Hotel Q Star v. Deputy Commissioner

Bench: Karnataka High Court
Date: 11 December 2025
Sections engaged: 143(3), 147, 148, 148A(b), 148A(d), 156, 271A, 274
Procedural ground: Writ challenge to the 148A(b) show-cause notice and the consequential 148A(d) order; the High Court examined whether the AO had complied with the mandatory hearing under Section 148A(b) before passing the speaking order.

4. Ameerul Shabaz v. Deputy Commissioner of Income Tax

Bench: Karnataka High Court
Date: 28 November 2025
Sections engaged: 143(3), 147, 148A(b), 148A(d), 156, 270, 271(1), 271A, 274
Procedural ground: Challenge to the 148A(b) show-cause notice and the speaking order under 148A(d). The High Court tested whether the assessee had been provided the information relied upon by the AO, as the proviso to 148A(b) requires.

5. Somnath Kannure, Pune v. Income Tax Officer Ward 1(1), Pune

Bench: Income Tax Appellate Tribunal, Pune
Date: 21 April 2026
Sections engaged: 147, 148, 148A, 148A(d), 149, 151, 151(i), 151(ii), 250
Procedural ground: The assessee challenged the validity of the Section 151 sanction, drawing the distinction between 151(i) (sanction within 3 years) and 151(ii) (sanction beyond 3 years requiring approval of the Principal Chief Commissioner / Chief Commissioner / Principal Director General / Director General). Sanction at the wrong tier is treated as no sanction at all.

6. Sachin Mohanlal Chordia, Pune v. Income Tax Officer Ward 5(1), Pune

Bench: Income Tax Appellate Tribunal, Pune
Date: 30 March 2026
Sections engaged: 11, 139, 147, 148, 148A, 149, 151, 151(i), 250, 4, 50
Procedural ground: Reassessment notice tested against Section 149 limitation (3-year vs 10-year window) and Section 151 sanctioning authority. Bench applied the Rajeev Bansal (Supreme Court) framework on the limitation arithmetic post the Finance Act 2021 transition.

7. M/S Indian Yarns Ltd v. ACIT and Anr

Bench: Delhi High Court (Orders)
Date: 18 August 2022
Sections engaged: 148, 148A(b), 148A(d)
Procedural ground: An early post-2021-amendment writ where the Delhi HC examined the procedural sufficiency of the 148A(b) show-cause and 148A(d) order. Frequently cited in subsequent reassessment writs.

8. Hitech Poultry Feeds, Puttur v. Income Tax Officer, Puttur

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 ground: Challenge to the reassessment proceedings combined with penalty notices under 271B / 272A(1)(d). Bench evaluated the validity of the 148A foundation before reaching the penalty grounds.

9. Income Tax Officer, Jaipur v. Pooja Kedia, Jaipur

Bench: Income Tax Appellate Tribunal, Jaipur
Date: 7 August 2025
Sections engaged: 131, 132(4), 142(1), 147, 148A, 148A(b), 40, 68, 80
Outcome: Taxpayer succeeded (revenue's appeal dismissed)
Procedural ground: Revenue appealed against deletion of additions under Section 68 and disallowance of interest on loans. The bench upheld the CIT(A)'s order, dismissing the revenue's grounds. The 148A foundation was tested as part of the broader proceeding.

10. Sonu Agarwal, Jaipur v. Income Tax Officer Ward 1(3), Jaipur

Bench: Income Tax Appellate Tribunal, Jaipur
Date: 19 November 2025
Sections engaged: 10(38), 115B, 139, 142(1), 147, 148, 148A, 148A(d), 250, 49, 69A, 80
Outcome: Taxpayer succeeded — appeal allowed
Procedural ground: The reassessment notice and the consequential order were quashed. The bench expressly held "Decided in favour of assessee" and "Appeal of the Assessee is allowed" on the validity of the reassessment proceeding.

11. Dinesh Dilip Mehta, Pune v. Income Tax Officer Ward-7(1), Pune

Bench: Income Tax Appellate Tribunal, Pune
Date: 30 April 2025
Sections engaged: 147, 148, 148A, 148A(a), 148A(b), 148A(d), 151, 250, 56, 69, 8
Outcome: Partial relief
Procedural ground: The legal ground was allowed: the order under Section 148A(d) and the notice under Section 148 were quashed. Other substantive grounds were dismissed as unadjudicated, since the jurisdictional ground had already disposed of the proceeding.

What recurs across these 11 rulings

Three patterns repeat in the procedural reasoning of the benches:

Section 151 sanction defects. Either the wrong sanctioning authority (151(i) vs 151(ii) tier confusion), missing sanction altogether, or sanction not communicated to the assessee. Sanction at the wrong tier is treated as no sanction.
148A(b) hearing not effective. Either the information relied upon was not furnished, the response window was less than 7 days, or the AO did not deal with the assessee's reply in the 148A(d) order.
Faceless Scheme (Section 144B / 151A) bypass. Notices issued by the jurisdictional AO instead of through the faceless mechanism after 1 April 2021 were quashed on the strength of the Hexaware Technologies line of decisions.

How to use this compilation

For research purposes, this index is a starting point for finding citations on specific procedural objections. Each case name above can be searched on indiankanoon.org or the relevant court's official portal to access the full text of the judgment. Pin the judgment date and the bench when verifying — court treatment of the same legal issue can vary materially between High Courts and across ITAT benches.

If you are advising on a live reassessment matter, three threshold checks before relying on any of the above:

Confirm the judgment has not been stayed, reversed, or distinguished by a higher bench.
Read the full reasoning rather than the catchwords — the procedural defect quashed in one case may be cured by AO conduct in another.
Check for parallel CBDT instructions or notifications that address the procedural point post-judgment.

Source

All 11 cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings as of May 2026), sourced from indiankanoon.org and the official ITAT / High Court / Supreme Court portals. The "sections engaged" field is auto-extracted from the judgment text and may include both the operative provisions and procedural sections referenced in passing.

Section 148A Quashing: 11 ITAT & High Court Rulings (2024–2026)