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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


Reopening for Depreciation Claim: SC Dismisses Revenue Appeal Over Delayed Filing

December 11, 2025 645 Views 0 comment Print

The Gujarat High Court held that the assessee disclosed all material facts and the reopening notice under section 148/147 was a change of opinion, lacking jurisdiction.

Faceless Assessment Prevails: JAO’s Reassessment Notice Invalid, Revival If SC amends Law

December 11, 2025 1020 Views 0 comment Print

Tribunal held that a notice issued by JAO under Section 148 is invalid, emphasizing that only FAO-issued notices comply with faceless reassessment rules. Revenue may seek revival if Supreme Court changes legal position.

Same-Day 153D Approval Invalidates Section 153A Assessments

December 10, 2025 891 Views 0 comment Print

ITAT held that mass same-day approval without reviewing records violated Section 153D. The ruling confirms that mechanical approvals invalidate 153A assessments.

AO Mistake on ROI Leads to Section 54F Reassessment Remand

December 10, 2025 240 Views 0 comment Print

ITAT ruled that reopening assessment under Section 147 is invalid if the filed return is ignored. The case was remitted for fresh consideration after allowing the assessee to substantiate claims under Section 54F.

Penny-Stock Reassessments Upheld, But Ex-Parte Orders Set Aside

December 10, 2025 279 Views 0 comment Print

The Tribunal held that reopening under Section 147 was legally sound and unaffected by arguments based on 153C or Notification 18/2022. Still, it directed a full rehearing because the appellate authority issued non-speaking orders without examining the merits.

Sale Proceeds Cannot Be Taxed as Income Without Capital Gains Computation

December 10, 2025 792 Views 0 comment Print

ITAT Hyderabad rules that gross sale proceeds of capital assets cannot be treated as taxable income without allowing cost of acquisition. Tribunal orders reassessment to compute correct capital gains, despite assessee’s non-compliance.

Manual Section 148 Notices Violate CBDT Escaping Assessment Scheme

December 10, 2025 564 Views 0 comment Print

The ITAT held that reassessment notices must be issued through NFAC under the 2022 Faceless Scheme. A JAO-issued notice violates the mandatory procedure and stands invalid.

Non-Speaking CIT(A) Order Quashed; IDS & JDA Issues Re-Examined

December 10, 2025 228 Views 0 comment Print

Tribunal quashed CIT(A)’s cryptic order that upheld addition based solely on IDS declaration. The case is remanded to ensure a fair hearing, full analysis of the Joint Development Agreement, and accurate determination of tax liability.

Non-Speaking Order Set Aside – ITAT Sends ₹7.26 Cr Capital-Gain Dispute Back to CIT(A)

December 10, 2025 171 Views 0 comment Print

The Tribunal held that the CIT(A) failed to give a reasoned order on land ownership and capital-asset status. The case is remanded for fresh adjudication and proper hearing.

Tribunal Upholds JAO Reassessment Despite Faceless Procedure Requirement

December 10, 2025 507 Views 0 comment Print

ITAT Agra held that reassessment under Section 144 by JAO is valid even though faceless procedure under Section 144B was generally applicable. The CBDT Circular of 17.03.2022 provided relaxation for cases with expiring limitation. CIT(A)’s non-est finding was set aside, ensuring compliance with procedural exceptions.

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