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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


ITAT Rejects Revenue’s Addition Based Only on Third-Party Statement

December 12, 2025 996 Views 0 comment Print

Mumbai ITAT ruled that retracted statements of a third-party transporter cannot justify additions without corroborative material. Detailed invoices, delivery challans, and proof of goods movement demonstrated genuine business expenses, resulting in dismissal of Revenue appeals.

Section 148 Notice Issued After Limitation Period Declared Invalid

December 12, 2025 705 Views 0 comment Print

ITAT held that reassessment notices issued after the surviving period, as clarified by Rajeev Bansal, are time-barred for AY 2015-16. The ruling emphasizes that procedural compliance with limitation periods is mandatory, even if notices are issued under unamended law.

Invalid Sanction Kills Reopening: ITAT Says PCIT Cannot Replace JCIT Under Old Section 151(2)

December 12, 2025 519 Views 0 comment Print

The Tribunal emphasized that for notices issued before 01.04.2021, the sanctioning power rested solely with the JCIT, making the PCIT’s approval invalid. Consequently, the ₹82.89 crore disallowance and all further proceedings were set aside.

276CC Prosecution: HC Upheld Income Tax Dept Notices Under Section 91 Cr.P.C.

December 12, 2025 450 Views 0 comment Print

The court upheld the trial court’s decision permitting the Income Tax Department to place additional notices on record. Key takeaway: Section 91 Cr.P.C. may be invoked at any stage for documents necessary for fair adjudication.

Rajasthan HC: Reassessment Quashed as Section 148 Notice Issued by JAO

December 12, 2025 543 Views 0 comment Print

The Court held that a Section 148 notice issued by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer was invalid, resulting in the reassessment order being set aside.

Reopening Beyond Four-Year Limit Invalid if Original Assessment Fully Disclosed Facts

December 12, 2025 525 Views 0 comment Print

Gujarat High Court held that reopening assessment beyond four years is invalid when all material facts were disclosed. Depreciation claims on Slump Sale assets remain intact.

ITAT Bangalore Upholds Tax on Waived Trade Liabilities and Unexplained Purchases

December 12, 2025 216 Views 0 comment Print

The Tribunal held that once the assessee’s own ledger reflected a creditor’s write-off, Section 41(1) was automatically triggered. The waiver in books = taxable cessation of liability.

Section 148 Notice Quashed for Breach of Faceless Reassessment Requirement

December 12, 2025 1149 Views 0 comment Print

The Court found that reassessment must proceed through the faceless regime and not through a jurisdictional officer. Since the notice was issued in breach of this mandate, both the notice and assessment order were quashed.

ITAT Rules Employer Advances Cannot Be Treated as Unexplained Money Without Verification

December 12, 2025 270 Views 0 comment Print

The Tribunal held that employer-provided business advances cannot be classified as income under Section 69A without proper verification, remanding the case for limited review of TDS and expense records.

Assessment Under Section 147/144 Struck Down for Not Issuing Section 143(2) Despite Valid Return

December 11, 2025 936 Views 0 comment Print

The Tribunal found that even a belated return filed in response to a Section 148 notice remains a valid return requiring a 143(2) notice. Because this mandatory notice was never issued, the reassessment order was declared illegal and set aside.

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