This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings pronounced in August 2026, each of which engaged Section 142(1) of the Income Tax Act, 1961 as part of their procedural or substantive framework. The cases span benches at Hyderabad, Delhi, Bangalore, and Ahmedabad, and arise across a range of associated provisions including reassessment, best-judgment assessment, search and seizure, block-period assessments, penalty proceedings, and exemption claims. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured, bench-wise reference point for matters where Section 142(1) notices feature in the procedural history.

Research index only. This page is a structured case-law reference compiled from the TaxNoticeAI legal corpus. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Readers should verify all citations against the full text of the original judgment before relying on them.

The statutory framework in one paragraph

Section 142(1) of the Income Tax Act, 1961 empowers the Assessing Officer, for the purpose of making an assessment, to serve a notice on a person who has filed a return of income or, before the end of the relevant assessment year, on a person who has not filed a return, requiring that person to produce, or cause to be produced, such accounts or documents as the Assessing Officer may require, or to furnish in writing and verified in the prescribed manner information on such points or matters as the Assessing Officer may specify. The section operates at the inquiry stage, prior to the completion of assessment, and is a foundational procedural tool across scrutiny assessments, best-judgment assessments, and post-search proceedings. Non-compliance with a notice issued under this section can have consequences under other provisions of the Act, and the validity of the underlying notice and the procedure followed in issuing it have been contested in a range of appellate proceedings.

The 12 rulings

1. Namademudu Gurrapu,Hyderabad vs ITO, Ward-13(3), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 21 August 2026
Sections engaged: 133(6), 142(1), 144, 147, 148, 148A(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee before the Income Tax Appellate Tribunal, Hyderabad Benches, and is directed against the order passed by the Commissioner (per the source preview, the order text is truncated at that point). The matter is identified in the source as ITA 427/HYD/2026 for Assessment Year 2016-2017, with the procedural framework engaging, among other provisions, reassessment-related sections alongside the inquiry notice provisions.

2. Income Tax Officer, Ward-1, Nalgonda vs Iddaiah Varikuppala, Nalgonda

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 21 August 2026
Sections engaged: 142(1), 144, 147, 148, 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The present appeals were filed by the Revenue and are directed against the respective orders passed by the Commissioner of Income Tax (per the source preview, the order text is truncated at that point). The source identifies these as ITA 1519/HYD/2025 and ITA 1569/HYD/2025 for Assessment Year 2013-14, with the sections engaged spanning best-judgment assessment, reassessment, and penalty proceedings.

3. Rupee Soren L/H Of Shibu Soren,New Delhi vs ACIT Central Circle 6, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 21 August 2026
Sections engaged: 139(1), 142(1), 143(2), 143(3), 143(i), 144, 145, 158B, 292B
Outcome: Outcome not specified in source
Procedural / substantive ground: According to the source preview, the first issue in this appeal concerned the assumption of jurisdiction for the framing of a block-period assessment without issuing a notice under Section 143(2) of the Act after the filing of a return of income for the block period pursuant to a notice under Section 158BC. The source records that a search and seizure operation under Section 132 of the Act had been carried out, and the matter is identified as IT(SS) A No. 100/Del/1997 covering the block period 1 April 1986 to 26 April 1996.

4. Mohit Kumar Gupta,Delhi vs Deputy Commissioner Central Circle 7

Bench: Income Tax Appellate Tribunal - Delhi
Date: 21 August 2026
Sections engaged: 115, 127, 131, 132, 132A, 142(1), 143(2), 143(3), 153(1), 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITSSA 8029/DEL/2025 for AY 2021-22 arises out of the order of the Commissioner of Income Tax (Appeals)-24, Delhi, per the source preview. The matter involves a search-related assessment framework, with the procedural history engaging provisions relating to search and seizure as well as the inquiry and assessment machinery. The source preview is truncated before substantive findings are set out.

5. Veerabhadrappa vs Income Tax Officer, Ward 1

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 21 August 2026
Sections engaged: 142(1), 144, 250, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee before the Income Tax Appellate Tribunal, Bangalore Benches, and is identified in the source as ITA 2400/BANG/2026 for Assessment Year 2017-18. The procedural framework engages best-judgment assessment provisions alongside the inquiry notice provisions; the source preview is truncated before the substantive findings of the order are set out.

6. Siriwara Sanna Rudrappa,Kappagal vs Income Tax Officer, Ward 1, Ballari

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 21 August 2026
Sections engaged: 115B, 127, 133(6), 142(1), 144, 250, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee before the Income Tax Appellate Tribunal, Bangalore Benches, and is identified in the source as ITA 1071/BANG/2026 for Assessment Year 2017-18. The sections engaged include provisions relating to unexplained money, best-judgment assessment, and inquiry notices; the source preview is truncated before the substantive reasoning of the order is set out.

7. Mohmed Safi Abdulrehman vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 20 August 2026
Sections engaged: 129, 139(1), 142(1), 143(1), 143(2), 250, 68
Outcome: Outcome not specified in source
Procedural / substantive ground: According to the source preview, one of the grounds raised by the assessee (Ground No. 4) was that the assessment order was bad in law and without jurisdiction, as the return of income had been accepted by one Assessing Officer while the notice under Section 143(2) was issued by a different Assessing Officer, and the subsequent proceedings and assessment order were carried out by yet another Assessing Officer without any valid transfer order. The matter is identified as ITA No. 1522/AHD/2026 for Assessment Year 2013-14.

8. Revelation Unique Retail And Marketing vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 115B, 127, 132, 142(1), 153C, 234B, 250, 272A(1)(d), 274, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: According to the source preview, the appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-25, Delhi dated 09.01.2025, arising out of an assessment order dated 10.03.2023 for assessment year 2020-21. The matter is identified as ITA No. 1036/Del/2025 and the procedural framework involves a search-related assessment context; the source preview is truncated before the substantive findings are set out.

9. Shivramegowda Rampura vs Income Tax Officer Ward 1(2) Mysore

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 19 August 2026
Sections engaged: 115B, 142(1), 143(2), 143(3), 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed the present appeal before the Income Tax Appellate Tribunal, Bangalore Benches, and the matter is identified in the source as ITA 2313/BANG/2026 for Assessment Year 2017-18. The sections engaged include scrutiny assessment provisions alongside the inquiry notice framework; the source preview is truncated before the substantive findings of the order are set out.

10. Vinod Kumar Gupta,Delhi vs ACIT, Central Circle- 27, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 142(1), 147, 148(b), 148A, 148A(b), 149(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: According to the source preview, both appeals (ITA No. 4461/Del/2025 for Assessment Year 2016-17 and ITA No. 4462/Del/2025 for Assessment Year 2015-16) were time-barred by 168 days. The Tribunal condoned the delay upon the assessee demonstrating sufficient cause, noting that an entrusted person before the NFAC had failed to inform the assessee of the order passed. The assessee also filed applications to raise additional legal grounds described as pure questions of law going to the root of jurisdiction, in the context of the reassessment framework.

11. M/S. China Construction Sausum (I) Pvt vs DCIT Central Circle 13, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 127, 132, 133(6), 142(1), 143(2), 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: According to the source preview, the assessee company is engaged in the execution of civil and industrial construction. The appeals are identified as I.T.A. Nos. 7866 & 7867/Del/2025 for Assessment Years 2020-21 and 2021-22. The source preview notes that certain grounds raised by the assessee were stated to be not pressed at the time of hearing and were dismissed accordingly; the procedural framework engages search-related assessment provisions alongside the inquiry notice machinery.

12. Jogdhian Hari Bhagwan Rastogi vs ITO Ward Exemption 1(4), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 19 August 2026
Sections engaged: 11(5)(iii), 142(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: According to the source preview, this matter involves a charitable trust and the appeal is identified as I.T.A. No. 8317/Del/2025 for Assessment Year 2013-14. The learned counsel for the assessee stated at the outset that due to an inadvertent mistake in filing the return of income electronically, a claim in respect of investment of sale proceeds in the acquisition of a new capital asset in mutual funds could not be made properly, and that the claim was subsequently made during the course of scrutiny assessment proceedings but was not accepted; the source preview is truncated at that point.

Patterns across these 12 rulings

Section 142(1) as a procedural anchor across diverse substantive disputes. Across all twelve rulings, Section 142(1) appears as part of the procedural chain rather than as the sole or primary substantive issue. In cases involving best-judgment assessments (Cases 1, 2, 5, 6), reassessment (Cases 1, 2, 10), search-related assessments (Cases 3, 4, 8, 11), and scrutiny assessments (Cases 7, 9, 12), the inquiry notice provision features as a step in the procedural history that is cited alongside the central provision under challenge.
Jurisdictional and procedural validity challenges are a recurring theme. At least two rulings from the source data directly raise jurisdictional grounds: in Case 3, the central issue was whether an assessment for a block period could be framed without issuing a notice under Section 143(2) after a return was filed; in Case 7, the assessee challenged the assessment as without jurisdiction because different Assessing Officers issued the Section 143(2) notice and carried out the subsequent proceedings without a valid transfer order. This pattern suggests that practitioners regularly contest the procedural regularity of the notice chain as a threshold ground.
Best-judgment assessments frequently co-occur with Section 142(1) notices. Section 144 (best-judgment assessment) appears alongside Section 142(1) in Cases 1, 2, 5, and 6, consistent with the statutory scheme under which a best-judgment assessment can follow non-compliance with an inquiry notice. This co-occurrence is visible across both the Hyderabad and Bangalore benches in this set.
Delay condonation as a preliminary procedural issue. Case 10 illustrates that delay in filing appeals before the Tribunal — in that instance, 168 days — can itself become a preliminary issue requiring adjudication before the substantive grounds are reached. The Tribunal in that case condoned the delay on the basis of an affidavit demonstrating sufficient cause, reflecting an established procedural practice at the appellate stage.
Geographic spread with concentrated activity in Delhi and Bangalore benches. Of the twelve rulings, five were pronounced by ITAT Delhi, three by ITAT Bangalore, two by ITAT Hyderabad, and one by ITAT Ahmedabad. All twelve were pronounced within a three-day window (19–21 August 2026), reflecting high appellate volumes at these benches during this period.

How to use this compilation

This index is designed to serve as a first-pass research tool for identifying ITAT rulings that engage Section 142(1) in a given procedural context. When using this compilation, researchers should begin by identifying the specific procedural or substantive intersection most relevant to the matter under examination — for example, whether the Section 142(1) notice features alongside a reassessment provision, a search-related provision, or a best-judgment assessment — and then locate the relevant case entries accordingly. The "Sections engaged" field for each case provides the full list of provisions cited in the source data, which can guide researchers toward cases with the closest procedural alignment.

Researchers must verify all references against the full text of the original judgment before placing reliance on any entry in this index. The source previews available in the underlying corpus are, in several cases, truncated before the substantive reasoning or operative portion of the order is reached. Accordingly, the outcome, reasoning, and holding of a significant number of these rulings cannot be confirmed from the source preview alone, and the "Outcome not specified in source" designation should be treated as a prompt to retrieve the complete judgment from indiankanoon.org or the relevant official court portal. Researchers should also check whether any ruling in this index has been subsequently stayed, reversed, or distinguished by a higher forum.

In addition to verifying the judgment text, researchers should check for any CBDT instructions, circulars, or notifications that may have amended or clarified the procedural requirements under Section 142(1) for the relevant assessment year. The interaction between statutory amendments — including changes to the reassessment framework introduced in recent Finance Acts — and the procedural validity of notices issued under Section 142(1) has been a live area of litigation, and the applicable legal position may differ depending on the assessment year in question. Cross-referencing the sections engaged in each case against the version of the Act in force for the relevant assessment year is accordingly an important step in any research exercise.

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 142(1) Income Tax Notices: 12 ITAT Rulings (2026)