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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


LTCG Claim Reopened Due to Preferential Allotment Concerns

January 16, 2026 819 Views 0 comment Print

The Tribunal held that shares acquired directly from promoters through preferential allotment require strict scrutiny when linked to abnormal price rise. Failure to establish commercial rationale justified restoring the matter for fresh verification.

Extended Limitation Cannot Apply to Expense Disallowances

January 16, 2026 948 Views 0 comment Print

The Tribunal clarified that expenditure disallowances do not qualify as assets under section 149(1). Without asset-based escaped income, reopening beyond three years is barred. This offers strong protection against belated reassessments.

ITAT Kolkata Quashed Reassessment for Borrowed Satisfaction in Share Capital Case

January 15, 2026 372 Views 0 comment Print

The Tribunal held that reopening based solely on third-party information without independent application of mind is invalid. Income escaping assessment must be based on the Assessing Officer’s own reason to believe.

Reassessment Issued to Deceased Person Held Void Ab Initio

January 15, 2026 675 Views 0 comment Print

The Tribunal held that a reassessment notice issued years after the assessee’s death is a legal nullity. Such proceedings are void even if the department was not informed about the death.

Accommodation Entry Cases: Full Addition Applies Without Proof

January 15, 2026 1470 Views 0 comment Print

Mumbai ITAT held that unexplained bank credits are fully taxable under Section 68 when beneficiaries of accommodation entries are not identified. Mere claim of acting as an entry operator does not limit addition to commission income.

Borrowed Satisfaction from Investigation Wing Not Permissible

January 15, 2026 1386 Views 0 comment Print

The Tribunal ruled that reassessment based on borrowed satisfaction, without inquiry or verification by the AO, is unsustainable. Independent application of mind is mandatory under the new regime.

Cash Deposit Reassessment Set Aside for Lack of Valid Sanction: ITAT Delhi

January 15, 2026 1611 Views 0 comment Print

Despite large additions for alleged unexplained cash deposits, the Tribunal quashed the reassessment itself. It reaffirmed that jurisdiction cannot be assumed without proper and reasoned approval.

LTCG on Firm Dissolution Sent Back for Fresh Verification

January 15, 2026 534 Views 0 comment Print

The Tribunal held that deletion of long-term capital gains without examining original partnership records was premature. The matter was remanded for fresh verification of facts and documents.

Electronic Evidence Requires Cross-Examination Before Addition: ITAT Delhi

January 15, 2026 441 Views 0 comment Print

The Tribunal held that additions based solely on third-party statements and seized digital data cannot survive without allowing cross-examination. The matter was remanded for fresh adjudication after granting due opportunity to the assessee.

Unexplained Investment Limited to Actual Payment Made in the Year: ITAT Mumbai

January 15, 2026 954 Views 0 comment Print

The Tribunal ruled that additions under section 69 cannot exceed the amount actually invested during the relevant year. Where most payments were loan-funded, only the year-specific payment required examination.

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