Nadeem Mohammed Iqbal Patni vs Income Tax Officer Ward 25(3)(1), Mumbai

Parties Involved

Facts Summary

The appellant, Nadeem Mohammed Iqbal Patni, filed an appeal against the order passed by the National Faceless Appeal Centre (NFAC), Delhi, which dismissed his appeal against the Assessment Order dated 11/10/2023 under Section 147 read with Section 144B of the Income Tax Act, 1961 for the Assessment Year 2015-2016. The appellant raised additional grounds challenging the validity of the reassessment proceedings initiated under Section 147 of the Act on the ground of lack of valid sanction under Section 151 of the Act. Specifically, the appellant contended that the notice dated 18/04/2022 issued under Section 148 of the Act was invalid as it was issued after 01/04/2021, in view of the concession made by the Revenue before the Hon'ble Supreme Court in the case of Union of India Vs. Rajeev Bansal [2024] 469 ITR 46 (SC). The appellant relied on the recent judgment of the Hon’ble Bombay High Court in the case of Cherian Nallathu Abraham Annamma vs. Income-tax Officer, International Tax, Ward-1(1)(1), Mumbai [2025] 179 taxmann.com 433 (Bombay)/[2025] 307 Taxman 367 (Bombay)[13-10-2025].…

Legal Issues

• 1. Validity of the reassessment proceedings initiated under Section 147 of the Act.
• 2. Validity of the notice dated 18/04/2022 issued under Section 148 of the Act.
• 3. Validity of the order dated 18/04/2022 passed under Section 148A(d) of the Act.
• 4. Validity of the assessment order dated 11/10/2023 passed under Section 147 read with Section 144 read with Section 144B of the Act.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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