This compilation indexes 12 recent rulings — 11 from the Income Tax Appellate Tribunal (across Kolkata, Jaipur, Raipur, Hyderabad, Mumbai, Chennai, and Agra benches) and 1 from the Calcutta High Court — all decided between June and August 2026 and each engaging Section 149(1) of the Income Tax Act, 1961. The rulings address the limitation period applicable to the issuance of notices for reassessment of income, including questions of "surviving period" computation, the interplay between Section 149(1) sub-clauses, and the procedural validity of notices issued under Section 148. This index is intended for use by in-house tax teams, Big-4 associates, and law firm researchers tracking the evolving litigation landscape around reassessment timelines.

Research index only. This page catalogues tribunal and court orders for reference purposes. It does not constitute legal or tax advice. Readers must verify all rulings against the full text of the judgment, check for any subsequent stays or reversals, and consult qualified advisors before acting on any information presented here.

The statutory framework in one paragraph

Section 149(1) of the Income Tax Act, 1961 prescribes the time limits within which a notice for reassessment under Section 148 may be issued by the Assessing Officer. Under the provision as amended with effect from 1 April 2021, no such notice shall be issued if three years have elapsed from the end of the relevant assessment year (the general limitation window under clause (a)), unless the case falls within the extended window under clause (b), which permits issuance up to ten years from the end of the relevant assessment year where the Assessing Officer has in his possession books of account or other documents or evidence which reveal that the income chargeable to tax represented in the form of an asset has escaped assessment and the amount of income escaping assessment is likely to amount to fifty lakh rupees or more. The section thus operates as an absolute bar on the issuance of a notice beyond the applicable period, and its interaction with the COVID-19 pandemic-era extension orders and the Supreme Court's ruling on "surviving period" has generated substantial litigation before tribunals and high courts.

The 12 rulings

1. Esaar India Ltd.,Mumbai vs I.T.O., Ward - 5(1), Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 5 August 2026
Sections engaged: 135A, 147, 147A, 148, 148A, 148A(b), 148A(d), 149(1), 151A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 2990/KOL/2025) was filed by the assessee against the order of the Commissioner of Income Tax (Appeals)-NFAC, Delhi passed under Section 250 of the Act for AY 2014-15, dated 25.08.2025. At the threshold, the Registry reported that the appeal was barred by limitation by 38 days; the assessee filed a condonation petition with an affidavit attributing the delay to the company's dependence on its Chief Financial Officer, Mr. Dipesh Mistry, who was responsible for taxation matters and whose heavy professional workload and inadvertent oversight across multiple statutory compliances contributed to the delay.

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 by the assessee against the order of the CIT(A), Jaipur 05, dated 28.10.2025. Per the source preview, the case of the assessee was reopened and assessment was framed, with an addition of Rs. 1,96,331/- made on account of unexplained interest income earned during the impugned year (AY 2015-16). The Assessing Officer was in possession of information gathered from a search and seizure operation conducted under Section 132 of the Act on 23.11.2021 in the case of another party, which formed the basis for initiating proceedings.

3. Amit Jain, Raipur,Raipur vs ITO-3(1), Raipur, Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 31 July 2026
Sections engaged: 147, 148, 148A, 148A(a), 148A(b), 148A(d), 149(1), 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 550/RPR/2026) was filed by the assessee against the CIT(A)-NFAC, Delhi order for AY 2014-15, emanating from an assessment order dated 26.05.2023. Per the source preview, the tribunal reproduced a chart specifying the relevant dates and found that the notice under Section 148 should have been issued on or before 19/07/2022 taking into consideration the "surviving period," but the notice was in fact issued on 28/07/2022, which was beyond the time allowed. The Revenue's representative submitted that the notice had been served in time, a contention the Bench proceeded to examine against the date analysis.

4. 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 directed against the order of the Commissioner of Income Tax (Appeals) for AY 2017-18. The source preview is primarily procedural in nature, setting out the cause title, ITA number, date of hearing (23 July 2026), and date of pronouncement (29 July 2026), with the substantive analysis not captured in the available preview text; the appeal was filed against the CIT(A) order concerning reassessment proceedings under Sections 147, 148, and related provisions.

5. M/S. Leela Lace Holdings Private vs DCIT, Circle 2(2)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 28 July 2026
Sections engaged: 147, 148, 148A, 148A(d), 149(1), 151(ii), 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 362/MUM/2026) was filed by the assessee against the order of the NFAC Delhi passed under Section 250 of the Act, with the date of the CIT(A) order being 17.11.2025, for AY 2016-17. The source preview establishes the procedural posture of the matter — a second-level appeal before the Tribunal — and identifies the relevant sections as including Section 149(1) and Section 151(ii) alongside the reassessment provisions; the substantive analysis is not captured in the available preview text.

6. Srinivasan Rajaraman,Kanchipuram vs ACIT, Circle-2(1), Trichy

Bench: Income Tax Appellate Tribunal - Chennai
Date: 21 July 2026
Sections engaged: 148, 149(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 909/Chny/2026) was filed by the assessee against the order of the CIT(A)-NFAC, Delhi dated 03.09.2025, for AY 2015-16. At the threshold, the Bench noted that the appeal was filed with a delay of 80 days and the assessee filed an affidavit explaining the reasons to condone the said delay; the Bench proceeded to peruse the same before addressing the substantive challenge to the reassessment proceedings under Sections 148 and 149(1).

7. Panaqua Tradecom Private Limited ( vs Income Tax Officer, Ashok Nagar

Bench: Income Tax Appellate Tribunal - Agra
Date: 17 July 2026
Sections engaged: 148, 148A, 149(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 199/Agr/2026) was preferred against the order dated 22.01.2026 passed in Appeal No. NFAC/2012-13/10281812 by the CIT(A)-NFAC Delhi for AY 2013-14, wherein the CIT(A) had remanded the matter back to the Assessing Officer for passing a fresh assessment order by invoking the proviso to clause 251(1)(a) of the Act. At the outset, the Bench noted that the assessee had raised as many as 17 grounds in the second appeal, with legal grounds including challenges to proceedings under Sections 148 and 148A read with Section 149(1).

8. Chandravadan Desai,Kolkata vs D.C.I.T., Circle - 32(1), Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 13 July 2026
Sections engaged: 149(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1009/Kol/2026) was preferred by the assessee against the order of the CIT(A)-NFAC, Delhi dated 02.03.2026 for AY 2017-18. Per the source preview, the assessee's representative pressed the legal issue that the order dated 27.07.2022 and the notice dated 28.07.2022 were barred by limitation as both were issued beyond the time available under the surviving period, in light of the decision of the Supreme Court in Union of India and Others vs. Rajeev Bansal [2024] 469 ITR 46 (SC) dated 03.10.2024, and urged the Bench to quash the impugned assessment order on this ground.

9. Deputy Commissioner Of Income Tax vs Royal Securities Limited, Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 10 July 2026
Sections engaged: 149(1), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter arose on ITA No. 2327/Kol/2025 filed by the Revenue along with Cross Objection No. 93/Kol/2025 filed by Royal Securities Limited (PAN: AABCR 4740 E) for AY 2016-17. The source preview sets out a detailed table of the respondent-assessee's transactions across multiple financial years, which appears to form part of the factual matrix relevant to the questions of escaped income and the applicability of the extended limitation period under Section 149(1)(b); the substantive analysis on the limitation question is not fully captured in the available preview text.

10. Prabaharan Dinesh Shankar,Dindigul vs ITO, Ward-1,, Dindigul

Bench: Income Tax Appellate Tribunal - Chennai
Date: 7 July 2026
Sections engaged: 148, 149(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1538/Chny/2026) was preferred by the assessee against the order of the CIT(A)-NFAC, Delhi dated 19.01.2026 for AY 2015-16. The source preview establishes the procedural identity of the matter, with the substantive challenge directed at reassessment proceedings under Sections 148 and 149(1); the full reasoning of the Bench is not captured in the available preview text.

11. Bheraram,Chennai vs ITO, Ncw-11(3), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 25 June 2026
Sections engaged: 148, 149(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1417/CHNY/2026) was filed by the assessee for AY 2015-16. Per the source preview, the assessee's representative submitted that the notice issued under Section 148 dated 07.04.2022 for AY 2015-16 was barred by limitation and therefore liable to be quashed, contending that in terms of the relevant provisions governing the limitation period, the notice had been issued outside the time permitted; the Bench proceeded to examine the contention against the applicable limitation framework.

12. Rahul Kumar Shaw vs Union Of India And Ors

Bench: Calcutta High Court
Date: 12 June 2026
Sections engaged: 148, 149(1), 148A(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WPO/909/2025) was filed before the Calcutta High Court challenging the legality, validity, and sustainability of a notice issued under Section 148 along with the order passed under Section 148A(3) dated 30 June 2025 by the Income Tax Officer for AY 2020-21. The source preview identifies two core issues framed by the Court: (i) whether the notice under Section 148 issued for AY 2020-21 was barred by limitation under Section 149(1) of the Act, given that it was issued after the expiry of three years and three months from the end of the relevant assessment year; and (ii) whether it was saved by the extended period of limitation on the ground that the income escaping assessment amounted to or was likely to amount to Rs. 50,00,000/- or more.

Patterns across these 12 rulings

"Surviving period" as a recurring battleground. Multiple rulings in this set — including the Raipur (Amit Jain) and Kolkata (Chandravadan Desai) matters — expressly engage the question of whether a notice was issued within the time remaining after computing the "surviving period" following the COVID-era extension orders and the Supreme Court's directions. The date-by-date chart methodology applied in at least one ruling illustrates how tribunals are conducting this arithmetic exercise on a case-by-case basis.
Rajeev Bansal (SC) as a pivotal reference point. The Chandravadan Desai ruling (ITAT Kolkata, case 8) expressly cites Union of India and Others vs. Rajeev Bansal [2024] 469 ITR 46 (SC) as the legal foundation for the limitation challenge. The frequency with which limitation challenges appear across this set suggests that the Rajeev Bansal decision continues to animate reassessment litigation across multiple benches and jurisdictions in 2026.
AY 2014-15 and AY 2015-16 as high-frequency assessment years in limitation disputes. Among the cases in this set for which assessment year data is available in the source preview, AY 2014-15 (cases 1, 3) and AY 2015-16 (cases 2, 6, 10, 11) appear with notable frequency. This reflects the operation of the limitation windows — notices for these years fall closest to the boundaries of the extended periods and are therefore most susceptible to limitation challenges.
Threshold procedural issues (delay in filing appeal) appearing alongside limitation challenges. In at least two rulings in this set (Esaar India Ltd. and Srinivasan Rajaraman), the Bench was required to address condonation of delay in filing the appeal before reaching the substantive limitation question. This pattern indicates that procedural compliance at the appellate stage is an independent issue layered on top of the underlying notice-validity dispute.
High Court writ jurisdiction invoked alongside ITAT proceedings. The Rahul Kumar Shaw matter (Calcutta High Court, case 12) demonstrates that limitation challenges to Section 148 notices are not confined to the appellate tribunal route — taxpayers are also invoking constitutional writ jurisdiction directly before High Courts, with the Court framing the two limbs of the Section 149(1) question (three-year general window vs. extended window for escaped income of Rs. 50 lakh or more) as the core issues for adjudication.

How to use this compilation

This index is designed as a first-pass research tool. Each entry identifies the forum, date, sections engaged, and the procedural or substantive ground drawn from the source preview. Because all twelve entries carry "Outcome not specified in source" as the outcome field, researchers should treat this compilation as a docket-level reference and must retrieve the full text of each judgment from the original source before drawing any conclusions about the holding, the direction of the order (whether the notice was quashed, upheld, or the matter remanded), or the reasoning adopted by the Bench. The full text will also confirm whether any interim stay was operating at the time of the order and whether any appeal to a higher forum has since been filed.

Researchers should additionally check for subsequent developments in each matter. Tribunal orders may be challenged before the relevant High Court under Section 260A of the Income Tax Act, 1961, and High Court orders may be appealed to the Supreme Court. An order pronounced in June or July 2026 may already have been stayed or reversed by the time this compilation is accessed. Cross-referencing with the CBDT's instructions, circulars, and press releases relating to the reassessment regime — particularly any administrative directions issued in the wake of the Supreme Court's ruling in Rajeev Bansal — is also recommended to understand the full regulatory context within which these rulings sit.

Finally, section numbers matter with precision in this area of law. The distinction between Section 149(1)(a) and Section 149(1)(b), or between Section 148A(b) and Section 148A(d), can be determinative of the outcome in a given case. When using this compilation to identify parallel rulings, researchers should filter by the specific sub-section or clause that is live in their matter, not merely by the parent section number.

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) Limitation on Reassessment Notices: 12 ITAT & HC Rulings (2026)