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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 294 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 699 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 291 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 285 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 58941 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


ITAT Mumbai: Invalid Section 148 Notice Leads to Deletion of Tax Demand

January 12, 2026 888 Views 0 comment Print

With the reassessment notice quashed, the consequential assessment order and demand were automatically annulled. The ruling highlights that taxpayers cannot be burdened where initiation itself is unlawful.

Motor Car Disallowance Deleted as Ownership & Business Use Proved: ITAT Mumbai

January 12, 2026 273 Views 0 comment Print

ITAT deleted disallowance of depreciation, loan interest, and fuel expenses after finding cars were registered in the company’s name. Ad-hoc personal use disallowance without evidence was held unsustainable.

Notice by Wrong Officer Invalid, ITAT Kolkata Set Aside Entire Assessment

January 12, 2026 582 Views 0 comment Print

Since the statutory notice under section 143(2) was issued by a non-jurisdictional officer, the assessment collapsed. The ruling affirms that valid notice by the competent authority is a sine qua non.

ITAT Bangalore Rejected Estimated Profit as Audited Books Showed Reasonable Margin

January 12, 2026 873 Views 0 comment Print

The Tribunal ruled that estimating higher profit without rejecting audited books or finding major defects is impermissible. The declared 7% margin was accepted as reasonable, emphasizing limits on ad-hoc profit estimation.

Reassessment Quashed for Lack of Assessee-Specific Evidence in Penny Stock Case

January 12, 2026 807 Views 0 comment Print

The Tribunal held that reopening based only on generalized information about a scrip, without independent inquiry or linkage to the taxpayer, is invalid. Entire addition on alleged bogus LTCG was deleted.

HP HC Stayed Reassessment as Validity of Section 148 Notices Pending Before SC

January 12, 2026 507 Views 0 comment Print

The High Court stayed reassessment proceedings after noting that the legality of Section 148 notices is under consideration before the Supreme Court. The key takeaway is that proceedings must await the apex court’s final ruling.

ITAT Mumbai Sustained Section 271(1)(c) Penalty for Unsubstantiated Expense Claims

January 12, 2026 708 Views 0 comment Print

The Tribunal examined whether a penalty could survive despite an allegedly vague notice. It held that since the assessment order and later notices clearly specified furnishing of inaccurate particulars, the penalty was valid.

Seized Jewellery Must Be Released After Full Tax Settlement: Gujarat HC

January 12, 2026 621 Views 0 comment Print

The High Court held that jewellery seized during a search cannot be retained once tax liability is fully settled under the Vivad Se Vishwas Scheme. Continued detention after issuance of Form-5 was declared illegal.

Reassessment Order Quashed for Granting Less Than Statutory Time to Reply

January 11, 2026 561 Views 0 comment Print

The Court examined a reassessment initiation where the assessee was given less than 24 hours to respond. Holding this to be contrary to Section 148A(b) and natural justice, the order and notice were quashed.

Calcutta HC Upheld Income Tax Reassessment as Earlier Order Formed No Opinion

January 11, 2026 576 Views 0 comment Print

The Court held that reassessment is not barred by change of opinion where the original issue was dropped due to absence of evidence. Subsequent reopening based on new material was found legally sustainable.

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