This compilation indexes 12 rulings pronounced between 13 July 2026 and 5 August 2026 by Income Tax Appellate Tribunal benches (Pune, Jaipur, Hyderabad, Delhi) and two High Courts (Gujarat and Madras) in matters where Section 149(1)(b) of the Income Tax Act, 1961 — the extended ten-year limitation period for reassessment notices — was among the sections engaged. It is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citation-ready index of recent adjudication on reassessment time-limit questions. Each entry reproduces the authoritative identity fields from the TaxNoticeAI corpus and provides a brief procedural note drawn exclusively from the corresponding source preview.

Research index only. This page is a structured case-law reference tool and does not constitute legal or tax advice. Readers must verify each ruling against the full authenticated judgment and check for any subsequent stays, reversals, or appeals before placing reliance on any entry below.

The statutory framework in one paragraph

Section 149(1)(b) of the Income Tax Act, 1961 prescribes the outer time limit within which a notice for reassessment under Section 148 may be issued where the income alleged to have escaped assessment amounts to or is likely to amount to fifty lakh rupees or more: in such cases the notice may be issued at any time within ten years from the end of the relevant assessment year, subject to the conditions set out in Section 148 and the satisfaction of the prerequisites in Sections 148A and 149 as amended by the Finance Act, 2021. The three-year limit in Section 149(1)(a) applies where the escaped income is below that threshold. The interplay between these two sub-clauses — and the procedural safeguards introduced by Section 148A requiring an inquiry and show-cause before issuance of a Section 148 notice — forms the central legal terrain across all rulings indexed below.

The 12 rulings

1. Kiran Krishnakumar Majithia,Sangli vs ITO Ward 3, Sangli

Bench: Income Tax Appellate Tribunal - Pune
Date: 5 August 2026
Sections engaged: 143(2), 148, 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 1830/PUN/2024) was filed by the assessee against the order of CIT(A)/NFAC passed under Section 147 read with Sections 144 and 144B, pertaining to Assessment Year 2018-19 (PAN: AAJHK9648H). Per the source preview, a ground of appeal challenges the confirmation of an addition of Rs. 76,70,555/- as estimated net profit on estimated sales of Rs. 9,58,81,939/-, with the assessee contending that evidence from Yashika Enterprise regarding purchases was ignored by the NFAC.

2. Manish Kumar Kotawala,Delhi vs DCIT, Central Circle-4, Jaipur, Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 4 August 2026
Sections engaged: 148, 148A, 149(1), 149(1)(b), 153A, 153C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1875/JPR/2025) was filed against the order of CIT(A), Jaipur, for Assessment Year 2015-16 (PAN: AIOPK2083K). Per the source preview, the case was reopened under Section 147 and an addition of Rs. 1,96,331/- was made on account of unexplained interest income; the Assessing Officer's information was gathered from a search and seizure operation conducted under Section 132 on 23.11.2021 in the case of a third party.

3. Satish Shantaram Mhaske,Nashik vs The ITO, Ward 1(1), Nashik, Nashik

Bench: Income Tax Appellate Tribunal - Pune
Date: 30 July 2026
Sections engaged: 149(1)(b), 250(6), 69
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1670/PUN/2026) was directed against the order dated 04-02-2026 of CIT(A)/NFAC, Delhi, under Section 250, pertaining to Assessment Year 2015-16 (PAN: AKCPM2192D). Per the source preview, the assessee is an individual engaged in trading of construction material (mainly sand) who did not file a return for AY 2015-16 on the ground that his income was below the taxable limit, and the Department initiated action based on information that the assessee had entered into transactions during that year.

4. Murali Kasturi,Hyderabad vs ITO, Ward-13(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 29 July 2026
Sections engaged: 142(1), 144, 144B, 147, 148, 148A, 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 1863/HYD/2025) was filed by the assessee against an order of the Commissioner of Income Tax (Appeals) for Assessment Year 2013-14 (PAN: AKYPK4845M). Per the source preview, the appeal arises from a reassessment proceeding; the source excerpt is largely procedural, with the full substantive grounds not reproduced in the available preview.

5. Adapa Venkateswarulu,Ongole vs ITO, Ward-1, Ongole

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 29 July 2026
Sections engaged: 144B, 147, 148, 148A, 148A(b), 148A(d), 149(1), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 944/HYD/2026) was filed by the assessee against the order of the Commissioner of Income Tax (Appeals) for Assessment Year 2017-18 (PAN: AXSPA4943M). Per the source preview, the appeal is directed against a reassessment order and the source excerpt is procedural in nature; the full substantive grounds are not reproduced in the available preview.

6. Sh. Diwakar Bhagwati Gandhi,Delhi vs Sh. Rajeev Kumar PCIT, Delhi-

Bench: Income Tax Appellate Tribunal - Delhi
Date: 29 July 2026
Sections engaged: 148, 149(1)(b), 263, 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 560/DEL/2026) was filed by the assessee against the order of the Principal Commissioner of Income Tax-4, New Delhi, dated 27.11.2025, arising out of an assessment order dated 26.05.2023 passed under Section 263 for Assessment Year 2015-16 (PAN: AAJPG3642B). Per the source preview, the source excerpt describes the appeal as raising a single issue arising from the revision order under Section 263, with the full substantive ground not reproduced in the available preview.

7. M/S Shivalik Packaging vs Assistant Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Delhi
Date: 24 July 2026
Sections engaged: 148, 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: These are seven consolidated appeals (ITA Nos. 7852 to 7858/Del/2025) filed by the assessee against the common order of CIT(A)-27, New Delhi, dated 11.09.2025, arising out of orders for Assessment Years 2017-18 to 2023-24 (PAN: ABRFS1990H). Per the source preview, the return of income was filed on 04.03.2019 declaring total income of Rs. 8,02,21,740/-, and thereafter a search and seizure action under Section 132 was carried out at the business premises of the assessee on 30.01.2024.

8. Indbro Biotech Private vs DCIT, Circle-12(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 22 July 2026
Sections engaged: 148, 149(1)(b), 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 629/HYD/2026) was filed by the assessee against the order of CIT(A) for Assessment Year 2015-16 (PAN: AABCI2706F). Per the source preview, one of the grounds raised is that the CIT(A) ought to have appreciated that an ex-parte assessment presupposes a reasoned best-judgment assessment based on due application of mind; the full substantive reasoning on the limitation ground is not reproduced in the available preview.

9. Income Tax Officer, Ward-48(1), New vs Ritu Jain, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 17 July 2026
Sections engaged: 148, 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 962/Del/2026) was filed by the Revenue against the order of CIT(A)/NFAC, Delhi, dated 04/11/2025, for Assessment Year 2013-14 (PAN: APXPJ5637G). Per the source preview, the assessee is an individual who filed her return on 23.3.2014 declaring total income of Rs. 2,53,340/- after Chapter VI-A deductions, and during the year under consideration she was found to be involved in trading of a penny stock scrip (Mahanivesh India Limited) resulting in a significant trade/sale value; this is a Revenue appeal, indicating the CIT(A) had decided the matter in the assessee's favour at the first appellate stage.

10. Sridevi Mogulla,Warangal vs ITO, Ward-1, Warangal

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 15 July 2026
Sections engaged: 148, 149(1)(a), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 496/HYD/2026) was filed by the assessee for Assessment Year 2016-17 (PAN: AKBPM9453E). Per the source preview, the assessee raised a ground that the Assessing Officer initiated reassessment for AY 2016-17 beyond three years even though the alleged escaped income as per the impugned assessment order was below Rs. 50,00,000/-, and challenged the notice under Section 148 and the reassessment as time-barred — specifically arguing the notice was time-barred under the three-year period applicable where escaped income is below the threshold, with the CIT(A) alleged to have erred in not upholding this objection.

11. Divyang Jayendrabhai Shah vs The Assistant Commissioner Of Income

Bench: Gujarat High Court
Date: 14 July 2026
Sections engaged: 148, 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/Special Civil Application No. 22214 of 2019) was filed before the Gujarat High Court at Ahmedabad seeking quashing and setting aside of a notice dated 28.03.2019 issued under Section 148 for reopening the assessment for AY 2012-13. Per the source preview, the petitioner is engaged in the business of trading of all types of ferrous, non-ferrous items, machinery, etc., and the writ was filed challenging the reassessment notice; the petition's disposition is not specified in the source preview.

12. Appnell Holdings Limited vs The Deputy Commissioner Of Income-Tax

Bench: Madras High Court
Date: 13 July 2026
Sections engaged: 148A(d), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P. No. 1513 of 2023, with W.M.P. No. 1662 of 2023) was filed before the Madras High Court under Article 226 of the Constitution of India, seeking a writ of certiorarified mandamus to quash the order dated 28.07.2022 passed under Section 148A(d) and the consequent notice under Section 148 issued on 28.07.2022 for Assessment Year 2015-2016, as arbitrary, ultra vires, and unconstitutional. Per the source preview, the petitioner also sought quashing of CBDT Instruction No. 01/2022 dated 11.05.2022 insofar as it authorised the relevant reopening action; the matter was reserved on 27.04.2026 and pronounced on 13.07.2026, with the full disposal not specified in the source preview.

Patterns across these 12 rulings

Limitation challenges are the central issue across multiple cases. At least cases 3, 4, 5, 9, 10, 11, and 12 show assessees or petitioners raising time-bar challenges to reassessment notices, with the core dispute being whether the notice was issued within the permissible period under Section 149(1)(b) (the ten-year extended window) or whether the shorter three-year period under Section 149(1)(a) applied because escaped income did not meet the threshold — most clearly articulated in case 10 (Sridevi Mogulla), where the source preview explicitly reproduces this ground of appeal.
Search-triggered reassessments feature in multiple matters. Cases 2 (Manish Kumar Kotawala) and 7 (M/S Shivalik Packaging) both involve reassessments linked to search and seizure operations under Section 132, with the question of which limitation and procedural regime applies to search-sourced information being a live issue alongside the Section 149(1)(b) time-limit question.
Section 148A pre-notice procedure appears alongside Section 149(1)(b) in several cases. Cases 2, 4, 5, and 12 cite Section 148A (including sub-clauses (b) and (d)) alongside Section 149(1)(b), reflecting the post-Finance Act 2021 framework in which a mandatory inquiry and show-cause under Section 148A must precede issuance of a Section 148 notice — with assessees contesting both the procedural compliance and the limitation period.
High Court writ jurisdiction is invoked where procedural defects in the notice are alleged. Cases 11 (Gujarat High Court) and 12 (Madras High Court) are writ petitions under Article 226 seeking to quash reassessment notices and orders at the pre-assessment stage itself, rather than pursuing the statutory appellate route — a pattern observed where the limitation or jurisdictional defect is said to go to the root of the notice.
Revenue appeals against first-appellate relief appear in the dataset. Case 9 (Income Tax Officer vs Ritu Jain) is an appeal by the Revenue, indicating the CIT(A)/NFAC had granted relief to the assessee at the first appellate stage; this is a recurring pattern in the broader reassessment litigation landscape where the Department challenges NFAC orders before the ITAT.

How to use this compilation

This index is organised by pronouncement date (most recent first within the article body) and covers rulings from July–August 2026 only. Researchers should treat each entry as a pointer to the full judgment rather than a self-contained statement of law. The source previews on which the procedural notes are based are extracts from the opening portions of the orders; the substantive reasoning, final operative directions, and any conditions attached to relief are contained only in the complete authenticated text available on indiankanoon.org and the respective court/tribunal portals.

Before placing reliance on any ruling listed here, researchers should: (a) obtain and read the full text of the judgment; (b) check whether the ruling has been subsequently stayed, appealed, or reversed — particularly for High Court orders, where a Special Leave Petition to the Supreme Court may be pending; (c) verify whether any parallel CBDT circular, instruction, or Finance Act amendment has altered the statutory position on Section 149(1)(b) applicable to the assessment year in question; and (d) confirm that the factual matrix of the ruling is genuinely comparable to the matter under research, given that limitation and procedural outcomes under Sections 148 and 149 are highly fact- and AY-specific.

For systematic research on the Section 149(1)(b) reassessment time-limit, this compilation should be read alongside CBDT Circular No. 01/2022 and the Finance Act, 2021 amendments to Sections 147–151, and cross-referenced against High Court decisions from other jurisdictions (Bombay, Delhi, Allahabad, Calcutta) that have pronounced on the same cluster of issues in earlier years. Patterns will continue to evolve as more 2026 rulings are indexed.

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 149(1)(b) & 148 Reassessment Time-Limit: 12 ITAT and HC Rulings (2026)