This compilation indexes twelve income-tax rulings — spanning the Income Tax Appellate Tribunal benches at Chennai, Rajkot, Ahmedabad, Hyderabad, and Delhi, as well as the Gujarat High Court and Calcutta High Court — all decided between June and June 2026, in which the limitation period prescribed under Section 149 for issuance of notices under Section 148 was a central or contributing issue. The compilation is intended as a structured research reference for in-house tax teams, Big-4 associates, and law firm researchers tracking how tribunals and High Courts are applying the post-Finance Act 2021 reassessment framework.

Research index only. This page reproduces publicly available case data for research and reference purposes. Nothing on this page constitutes legal advice, tax advice, or any form of professional recommendation. Readers must independently verify all rulings against the full judgment text and check for subsequent stays, appeals, or reversals before relying on any case.

The statutory framework in one paragraph

Section 149 of the Income Tax Act, 1961 prescribes the time-limit within which a notice under Section 148 for reassessment may be issued. As substituted by the Finance Act, 2021 with effect from 1 April 2021, the general limitation is three years from the end of the relevant assessment year. An extended limitation of ten years from the end of the relevant assessment year is available only where the income escaping assessment amounts to or is likely to amount to fifty lakh rupees or more and the Assessing Officer has in his possession books of account or other documents or evidence that reveal that income escaping assessment is of the specified magnitude. The Finance Act, 2021 also introduced Section 148A, which requires the Assessing Officer to conduct an inquiry and provide the assessee an opportunity to be heard before issuing a notice under Section 148. The interplay between Section 149's time-limits, the pre-condition procedure under Section 148A, and the transitional provisions under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 has generated substantial litigation, as reflected in the rulings indexed below.

The 12 rulings

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

Bench: Income Tax Appellate Tribunal - Chennai
Date: 25 June 2026
Sections engaged: 148, 149(1), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.1417/CHNY/2026) was filed against the Income Tax Officer for Assessment Year 2015-16. The appellant's advocate submitted that the notice issued under Section 148 dated 07.04.2022 for the assessment year 2015-16 is barred by limitation and therefore liable to be quashed, contending that the notice fell outside the permissible time-window under the relevant provisions of Section 149(1). The source preview indicates the limitation argument was the primary ground raised before the Tribunal.

2. Adesh Enterprise vs Union Of India

Bench: Gujarat High Court
Date: 25 June 2026
Sections engaged: 148, 148A(b), 148A(d), 149, 155, 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Special Civil Application No. 7313 of 2022, the petitioner challenged a notice issued under Section 148 for Assessment Year 2015-2016 under the old regime, placing reliance on the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and the limitation provisions under Section 149. The matter was heard by the Gujarat High Court at Ahmedabad and an oral judgment was pronounced on 25 June 2026; the source preview indicates the petitioner's challenge centred on whether the Section 148 notice issued under the old regime was saved or invalidated by the transitional provisions.

3. M/S Soham Techno Cast ,Rajkot vs Income Tax Officer Ward 2(1)(2)

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 22 June 2026
Sections engaged: 115B, 142(1), 147, 148, 148A, 149(1), 149(1)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 832/RJT/2025) relates to Assessment Year 2017-18 and arises from a reassessment proceeding. The source preview records that the assessee declared income of Rs.26,220/- for AY 2017-18 while a cash deposit of Rs.34,30,995/- (including Rs.25,30,995/- deposited during the demonetization period) appeared in the bank account, and that the assessee did not comply with notices. The appeal also engaged the limitation provisions under Section 149(1) and Section 149(1)(a), making the validity of the reopening a live issue in the proceedings.

4. Shri Swashrai Mahila Nagrik Dhiran Sewa vs The Dy. CIT, Circle-1(1)(1), Vadodara

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 16 June 2026
Sections engaged: 147, 148, 149(1)(a), 250, 80P
Outcome: Outcome not specified in source
Procedural / substantive ground: In ITA No. 1886/Ahd/2025 for Assessment Year 2017-18, the assessee co-operative raised the time-limitation question under the post-1 April 2021 regime as a ground of appeal. The source preview records the assessee's submission that under the Finance Act, 2021, the limitation period for issue of a notice under Section 148 / reopening under Section 147 is three years from the end of the relevant assessment year, except where escaped income is Rs.50 lakhs or more, and that since the alleged income escapement in this case was less than fifty lakhs, the Assessing Officer was bound by the three-year limit under Section 149(1)(a).

5. Bipinkumar Girdharlal Parekh vs Office Of The Assistant Commissioner Of

Bench: Gujarat High Court
Date: 15 June 2026
Sections engaged: 132, 143, 148(1), 148(3), 148A(1), 148A(3), 148A(d), 149, 151, 152(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Special Civil Application No. 15105 of 2025, the petitioner-assessee challenged the order dated 19.05.2025 passed under Section 148A(d) disposing of the petitioner's objections, as well as the consequential notice dated 23.05.2025 issued under Section 148 for Assessment Year 2021 (as indicated in the source preview). The writ petition before the Gujarat High Court at Ahmedabad engaged the limitation and procedural pre-condition framework under Section 149 alongside the Section 148A(d) order, and an oral judgment was pronounced on 15 June 2026.

6. 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. The petitioner's advocate 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 petition also engaged Section 149(1)(b) as part of the limitation challenge to the Section 148 notice.

7. Rahul Kumar Shaw vs Union Of India And Ors

Bench: Calcutta High Court
Date: 12 June 2026
Sections engaged: 141, 147, 148, 148A, 148A(3), 149(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: In WPO/909/2025, the petitioner challenged the notice under Section 148 along with the order passed under Section 148A(3) dated 30 June 2025 for Assessment Year 2020-21. The Calcutta High Court identified two core issues: first, whether the Section 148 notice 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 second, whether it was saved by the extended period of limitation on the ground that the income escaping assessment amounts to or is likely to amount to Rs.50,00,000/- or more.

8. The Bar Association City Civil Court vs ITO, Ward - 9(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 12 June 2026
Sections engaged: 142(1), 147, 148, 149(1), 149(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No.741/Hyd/2026) for Assessment Year 2015-16 was filed by the assessee society against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 18/12/2025, which in turn arose from the Assessing Officer's order under Section 147. The source preview indicates the appeal before the Tribunal engaged the limitation provisions under Section 149(1) and Section 149(1)(b) in connection with the validity of the reassessment proceedings.

9. Mallesh Reddy Nalla,Karimngar vs ITO Ward-2, Karimnagar

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 12 June 2026
Sections engaged: 142(1), 144B, 147, 148, 149(1), 149(1)(b), 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No.234/Hyd/2026) for Assessment Year 2015-16 was directed against the order of the CIT(A), National Faceless Appeal Centre, Delhi, dated 20/11/2025, which arose from the Assessing Officer's order under Section 147 read with Section 144B dated 19/01/2024. The assessee appeared without representation before the Tribunal; the source preview records that the appeal engaged the limitation provisions under Section 149(1) and Section 149(1)(b) as part of the challenge to the reassessment proceedings.

10. 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: The appeal (I.T.A. No.727/Hyd/2026) for Assessment Year 2015-16 was directed against the order of the CIT(A), National Faceless Appeal Centre, Delhi, dated 05/01/2026, which arose from the Assessing Officer's order. The assessee was unrepresented before the Tribunal. The source preview indicates the appeal engaged an extensive range of reassessment and limitation provisions including Section 148A(b), Section 148A(d), Section 149(1), and Section 149(1)(b), alongside sanction requirements under Section 151.

11. 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: The appeal (I.T.A. No.2427/Hyd/2025) for Assessment Year 2015-16 was filed against the order of the CIT(A), National Faceless Appeal Centre, Delhi. The source preview indicates the appeal engaged Section 149(1) and Section 149(1)(b) limitation issues in the context of the reassessment framework, alongside Section 148A(b) and Section 148A(d) procedural pre-conditions and sanction requirements under Section 151.

12. 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: The appeal (ITA No.5459/Del/2025) for Assessment Year 2014-15 involved the assessee challenging the CIT(A)'s order confirming 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. The source preview notes that the assessee is an individual who filed a return of income for AY 2014-15, and that the matter involved commodity trading on NSEL; the limitation provision under Section 149(1)(b) was engaged as part of the challenge to the reopening.

Patterns across these 12 rulings

Three-year versus extended limitation as the dominant dispute. Across multiple cases in this set — including Rahul Kumar Shaw (Calcutta HC), Shri Swashrai Mahila Nagrik Dhiran Sewa (ITAT Ahmedabad), and Bheraram (ITAT Chennai) — the central contested question is whether the Section 148 notice was issued within the standard three-year window under Section 149(1) or whether the extended limitation on account of escaped income of Rs.50 lakhs or more is attracted. This binary argument appears as a recurring structural feature of the litigation.
Assessment Year 2015-16 as a high-frequency target year. At least five of the twelve cases in this compilation — Bheraram, Bar Association City Civil Court, Mallesh Reddy Nalla, Mallareddy Donthi, and Madhavi Kompally — involve Assessment Year 2015-16 as the year under reassessment. This clustering is consistent with the limitation windows triggered by the transitional provisions introduced by the Finance Act, 2021 and the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.
Gujarat High Court as an active forum for writ challenges. Three of the twelve rulings — Adesh Enterprise, Bipinkumar Girdharlal Parekh, and M/S Touch Comm Tech Private Limited — are writ petitions before the Gujarat High Court at Ahmedabad, all engaging the Section 148A(d) order alongside Section 149 limitation arguments. The willingness of the Gujarat High Court to entertain such writ petitions at the pre-assessment stage is a visible pattern in the data.
Section 148A procedural pre-conditions appearing alongside Section 149 limitation grounds. In several cases — including Mallareddy Donthi, Madhavi Kompally, M/S Touch Comm Tech Private Limited, and Adesh Enterprise — the challenge to the reassessment notice combines the Section 149 time-bar argument with objections to the Section 148A(b) and Section 148A(d) process, indicating that assessees are routinely raising both procedural and limitation grounds together rather than relying on either alone.
Absence of assessee representation in multiple ITAT Hyderabad matters. In at least two of the Hyderabad ITAT cases in this set — Mallesh Reddy Nalla and Mallareddy Donthi — the source preview records that the assessee was unrepresented before the Tribunal. This is a procedural feature worth noting for researchers examining how limitation and reopening arguments are adjudicated when the assessee does not appear.

How to use this compilation

This compilation is organised as a structured index of publicly available judgment data. Each entry provides the identity fields (bench, date, sections, outcome direction) drawn from the source record, alongside a brief procedural note grounded in the available text preview. Because the text previews are drawn from the opening portions of the judgments, they may not reflect the full reasoning, all grounds raised, or the ultimate operative direction of the order. Researchers should locate and review the complete judgment text — available on indiankanoon.org or the relevant official court portal — before drawing any conclusions about the holding, the ratio, or the precedential value of a ruling.

When using this index for comparative research, researchers should verify whether any of the listed rulings have been subsequently stayed, appealed, reversed, or distinguished by a higher forum. Indian tax litigation moves quickly: a Tribunal ruling may be challenged before a High Court, and a High Court ruling may be the subject of a Special Leave Petition before the Supreme Court, within months of pronouncement. The TaxNoticeAI database is updated on a rolling basis, but the entries in this article reflect data as of the published date and may not capture subsequent developments.

Finally, researchers working on limitation questions under Section 149 should cross-reference the relevant CBDT circulars and instructions — including those issued in connection with the Finance Act, 2021 reassessment substitution and the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 — as these instructions have direct bearing on how Assessing Officers and tribunals apply the transitional limitation windows that underlie the majority of disputes indexed here.

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 Limitation for Reassessment Notices: 12 Rulings (2026)