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Section 148

Latest Articles


Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...

May 13, 2026 405 Views 0 comment Print

Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 759 Views 0 comment Print

Reassessment Invalid as AO Failed to Issue 143(2) Notice After Belated Return

Income Tax : ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143...

April 2, 2026 1140 Views 0 comment Print

Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 1866 Views 0 comment Print

Updated Return After Reassessment Notice Comes With Higher Tax Cost Because Additional 10% Levy Proposed

Income Tax : The Finance Bill 2026 proposes allowing taxpayers to file an Updated Return even after receiving a reassessment notice under Secti...

March 6, 2026 2373 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2286 Views 0 comment Print

Budget 2024: Amendments to Income-tax Assessment & Reassessment Provisions  

Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...

July 23, 2024 4404 Views 0 comment Print

Request to amend section 151 Sanctioning Authority for reassessment

Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...

July 25, 2022 6882 Views 0 comment Print

Request to clarify on SC judgement on Section 148 notices

Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...

May 12, 2022 7494 Views 0 comment Print

Indiscriminate Income Tax notices without allowing reasonable time

Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...

March 20, 2022 13347 Views 0 comment Print


Latest Judiciary


ITAT Indore Sets Aside Ex Parte CIT(A) Order as Notices Were Sent to Wrong Email Address

Income Tax : ITAT Indore held that appellate order violated principles of natural justice after finding that key hearing notices were sent to a...

May 22, 2026 108 Views 0 comment Print

Section 148 Notice Invalid as It Was Issued by JAO Instead of FAO: Rajasthan HC

Income Tax : Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2...

May 22, 2026 333 Views 0 comment Print

Madras HC Quashes Section 148 Notices as They Were Issued by Jurisdictional AO

Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...

May 22, 2026 780 Views 0 comment Print

Reassessment Notices Invalid as Faceless Procedure Was Not Followed: Madras HC

Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...

May 22, 2026 699 Views 0 comment Print

Jharkhand HC Upholds Reassessment Proceedings as Finance Act 2026 Inserted Section 147A Retrospectively

Income Tax : The Jharkhand High Court held that retrospective insertion of Section 147A removed the jurisdictional challenge against reassessme...

May 22, 2026 195 Views 0 comment Print


Latest Notifications


Income Tax Dept Flags High-Risk Transactions for Reassessment Action – Sections 148/148A

Income Tax : The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassess...

March 20, 2026 1026 Views 0 comment Print

ITO doesn’t have jurisdiction to issue notice to NRI: ITAT Chandigarh

Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...

April 11, 2025 5832 Views 0 comment Print

Guidelines for issuance of notice u/s 148 of the Income Tax Act, 1961

Income Tax : Explore the latest guidelines for issuing notice under Section 148 of the Income Tax Act, 1961. Understand key procedures, amendme...

June 28, 2024 57513 Views 0 comment Print

Instructions to AO’s for initiating Section 147 proceedings in e-Verification cases

Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...

March 1, 2024 5898 Views 0 comment Print

Limitation date for reopening cases related to Ashish Agarwal judgment

Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...

February 6, 2023 5910 Views 0 comment Print


Natural Justice Violated: Section 148A(d) Order Invalidated

December 20, 2025 267 Views 0 comment Print

Karnataka High Court quashed the Section 148A(d) order and Section 148 notice, allowing the assessee a fresh opportunity to submit documents and replies before reconsideration.

Section 148 Notice Invalidated for Genuine Non-Filing of Return

December 20, 2025 486 Views 0 comment Print

Karnataka High Court set aside reassessment and penalty orders where the assessee could not file returns due to inactive email, granting a fresh opportunity to submit documents and pleadings.

Reassessment Quashed for Lack of Opportunity to Reply to Section 148 Notice

December 20, 2025 300 Views 0 comment Print

The issue involved reassessment completed without a reply to the reopening notice. The Court set aside the orders and remanded the case to allow the assessee a fresh opportunity.

Reassessment Quashed for Initiation Outside Section 151A Scope

December 20, 2025 372 Views 0 comment Print

Karnataka High Court invalidated reassessment proceedings and related notices for AY 2015-16, holding that actions initiated beyond Section 151A are legally void.

Reassessment Quashed Because Section 151 Sanction Was Mechanical

December 20, 2025 660 Views 0 comment Print

The ITAT held that approval merely stating “Yes, I am satisfied” shows no application of mind. Such sanction fails the statutory requirement and invalidates reopening.

Repaid Loans and Bank Entries Can’t Trigger Section 68

December 20, 2025 639 Views 0 comment Print

The ITAT held that loans and advances accepted in earlier scrutiny assessments cannot be doubted later without fresh incriminating material. Mere balance-sheet analysis or suspicion is insufficient.

JAO Can’t Bypass Faceless Mandate – U/s 148 Notice Issued Outside Scheme Quashed

December 20, 2025 921 Views 0 comment Print

The ITAT held that a reassessment notice issued by the Jurisdictional AO after 29-03-2022 violated the mandatory faceless reassessment scheme. Such a jurisdictional lapse vitiates the entire proceedings.

Borrowed Satisfaction Invalidates Reopening Under Section 147

December 20, 2025 705 Views 0 comment Print

The ITAT held that reassessment based purely on an Investigation Wing report, without the Assessing Officer forming an independent belief, is invalid. Copy-pasted reasons failed to establish a live link between material and escapement of income.

388-Day Delay Condoned; Case Remanded for Fresh Hearing

December 20, 2025 216 Views 0 comment Print

The ITAT noted that cash-flow statements showing withdrawal–redeposit nexus were not examined. Non-consideration of material evidence warranted remand.

No Real Transfer, No Automatic U/s 50C Tax on Property Transaction

December 20, 2025 462 Views 0 comment Print

The ITAT held that capital gains under Section 50C cannot be mechanically applied where a sale deed is alleged to be an erroneous document and no real transfer occurred. The case was remanded to verify whether the transaction was actually a gift with no consideration or possession transfer.

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