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Section 148

Latest Articles


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 306 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 720 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 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


Addition Set Aside for Lack of Cross-Examination Opportunity

January 9, 2026 453 Views 0 comment Print

An addition based on a third-party statement was challenged for denial of cross-examination. The Tribunal held that natural justice must be followed and directed a fresh hearing.

Reassessment Quashed for Wrong Approval Under Section 151

January 9, 2026 810 Views 0 comment Print

The issue was whether reassessment beyond three years was valid without approval from the correct authority. ITAT held the notice void as sanction was taken from the wrong officer, reaffirming strict compliance with Section 151.

Reopening Quashed for Non-Supply of Material Relied Upon in Reasons

January 9, 2026 840 Views 0 comment Print

The issue was whether reopening is valid when the information relied upon is not shared. The Tribunal held that failure to supply such material violates natural justice and vitiates reassessment.

Section 40A(3) Disallowance Set Aside in Invalid Reassessment

January 9, 2026 291 Views 0 comment Print

The case examined whether reassessment after four years was valid when the issues were already examined in scrutiny. The Tribunal held the reopening invalid as a mere change of opinion and quashed the reassessment.

Reassessment Upheld Because Third-Party Excel Data Indicated Escaped Income

January 9, 2026 1428 Views 0 comment Print

The court held that an excel sheet found during a search, indicating a cash transaction, constituted valid information to reopen assessment.

Bogus Share Trading Loss Held Speculative, Set-off Denied

January 9, 2026 573 Views 0 comment Print

It was ruled that speculative losses from non-genuine share transactions cannot be adjusted against interest income. The decision reinforces strict application of sections 43(5) and 73 where delivery is doubtful.

Accrued MACT Interest Cannot Be Taxed When Award Is Under Appeal

January 9, 2026 642 Views 0 comment Print

Where compensation and interest are deposited under judicial custody due to a pending appeal, no real income accrues. The Tribunal ruled that taxing such MACT interest is impermissible until actual receipt.

Reassessment After Four Years Invalid for Change of Opinion: ITAT Chennai

January 8, 2026 525 Views 0 comment Print

The issue was whether reassessment could be initiated beyond four years after a completed scrutiny assessment. The Tribunal held that reopening was barred as there was no failure to disclose material facts.

Artificial profit/loss arising from client code modification requires transaction-wise reconciliation-Matter restored

January 8, 2026 435 Views 0 comment Print

ITAT Mumbai held that artificial profits or losses arising from Client Code Modification in share transactions carried out in F&O segment requires transaction-wise reconciliation. Accordingly, matter restore to the file of AO.

Reassessment Notice Quashed as Time-Barred After Supreme Court Ruling

January 8, 2026 909 Views 0 comment Print

The issue was whether a reassessment notice issued after the surviving limitation period was valid. The Tribunal held the notice time-barred in light of the Supreme Court ruling, rendering the entire reassessment invalid.

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