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Section 148

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ITAT Deletes On-Money Addition as Unsigned Agreement & Third-Party Records Lacked Evidence

Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...

June 30, 2026 333 Views 0 comment Print

Rectification, Assessment and Appeal under Income Act, 1961

Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...

June 29, 2026 14061 Views 0 comment Print

Can Updated Return Be Filed After Notice Under Sections 143(2), 148A or 148?

Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...

June 27, 2026 2829 Views 0 comment Print

SC Sends JAO vs Faceless Reassessment Dispute Back to High Courts

Income Tax : The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leavi...

June 27, 2026 498 Views 0 comment Print

Appellate Kill Shot to Reassessment Notices Under Section 148/148A

Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...

June 20, 2026 1056 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 2469 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 4584 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 6918 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 7524 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 13395 Views 0 comment Print


Latest Judiciary


Unaccounted sales must be taxed on net profit basis, not on gross profit: ITAT Delhi

Income Tax : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...

July 7, 2026 309 Views 0 comment Print

Section 56(2)(x) Applicability Depends on Agreement Date; Mistaken Tax Payment Refundable: ITAT Mumbai

Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...

July 6, 2026 726 Views 0 comment Print

APMC Commission Agent Not Taxable on Entire Sale Proceeds; Section 69A Issue Remanded: ITAT Bengaluru

Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...

July 6, 2026 297 Views 0 comment Print

1439-day delay in Filing Appeal Condoned & Matter Remanded for Fresh Assessment: ITAT Kolkata

Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...

July 5, 2026 291 Views 0 comment Print

Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...

July 5, 2026 228 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 1272 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 5961 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 58947 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 6018 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 5985 Views 0 comment Print


Writ dismissed as reassessment notice u/s. 148 held to be in time

January 16, 2026 564 Views 0 comment Print

Madras High Court held that reassessment notice under section 148 of the Income Tax Act for Assessment Year 2014-2015 issued on 29.07.2022 issued under new regime is held to be in time. Accordingly, writ petition stands dismissed.

Ex-Parte Appeal Dismissal Set Aside for Lack of Reasoned Order

January 16, 2026 402 Views 0 comment Print

The issue was whether the appellate authority could dismiss an appeal ex-parte without giving detailed reasons. The Tribunal held that a non-speaking order violates section 250(6) and restored the appeal for fresh adjudication.

Reassessment Quashed as JAO Lacked Jurisdiction After Faceless Scheme

January 16, 2026 2160 Views 0 comment Print

The issue was whether reassessment notices could be issued by a jurisdictional officer after the faceless reassessment scheme became mandatory. The Tribunal held that such notices are void, rendering the entire reassessment unsustainable.

Reassessment Quashed for Issuance of Notice Outside Faceless Regime

January 16, 2026 1977 Views 0 comment Print

The issue was whether reassessment could be initiated by a jurisdictional officer after faceless schemes became mandatory. The Tribunal held that notices issued outside the faceless mechanism lack jurisdiction and invalidate the reassessment.

Reopening After 3 Years Invalid If Escapement Is Below ₹50 Lakh

January 16, 2026 1722 Views 0 comment Print

Sanjay Champalal Jaiswal Vs ITO (ITAT Pune) Reopening Beyond Three Years Invalid Where Escapement Is Below ₹50 Lakh — ITAT Pune Quashes Reassessment The Pune SMC Bench of the ITAT quashed the reassessment for AY 2016-17, holding that the notice under section 148 dated 27-07-2022 was without jurisdiction, as the alleged income escaping assessment was […]

Section 263 Validly Invoked for Allowing Section 80P in Belated Return

January 16, 2026 678 Views 0 comment Print

The issue was whether deduction under section 80P could be allowed when the return was filed beyond the due date. The Tribunal held that non-compliance with section 80AC made the assessment erroneous, justifying revision under section 263.

Reopening Invalid When Search Material Triggers Section 153C

January 16, 2026 1239 Views 0 comment Print

The Tribunal held that when reassessment is based on material found during a third-party search, proceedings must be initiated under Section 153C and not Section 147. Reopening under Section 147 was therefore without jurisdiction and liable to be quashed.

Section 292B Cannot Cure Jurisdictional Defect in Reopening

January 16, 2026 819 Views 0 comment Print

The Assessing Officer assumed that no return of income was filed while recording reasons under section 147. The Tribunal ruled that such factually incorrect reasons vitiate the assumption of jurisdiction itself.

Interest Disallowance Set Aside as Loan Found Genuine

January 16, 2026 726 Views 0 comment Print

Interest was disallowed treating the loan as bogus. Once the loan itself was held genuine, the Tribunal allowed the interest deduction. The ruling confirms that business interest cannot be denied without proof of sham transactions.

Revenue Appeal Fails Due to Wrong Assessment Year for Cash Investment

January 16, 2026 645 Views 0 comment Print

Authorities added ₹8 crore as unexplained investment in the wrong year. The Tribunal confirmed that the cash component belonged to a prior year. The ruling stresses year-specific taxation of undisclosed transactions.

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