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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 14058 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 2823 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 1053 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

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 282 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 657 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 58938 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


Payer’s Expense Accepted, Payee Can’t Be Taxed Under Section 68

December 31, 2025 570 Views 0 comment Print

The reassessment was triggered without examining invoices, bank entries, TDS data, or business records. The Tribunal held that mechanical reopening based on external information is bad in law.

Revised compounding guidelines dated 17.10.2024 cannot be given retrospective effect

December 31, 2025 378 Views 0 comment Print

Madras High Court held that compounding charges payable by petitioner as per revised Guidelines dated 17.10.2024 is unsustainable since on the date of writ order i.e. 13.04.2022, the revised guidelines was not in force. Accordingly, writ petition deserved to be allowed.

Draft Reply Challenging Reopening Based on Photocopy Evidence

December 31, 2025 1047 Views 0 comment Print

The reassessment is challenged as being founded solely on an unauthenticated photocopy with no corroboration. Such material fails the “reason to believe” test and vitiates jurisdiction.

Post-2022 Reassessment Fails for Non-Compliance with Faceless Scheme

December 31, 2025 582 Views 0 comment Print

The Tribunal quashed reassessment proceedings where the section 148 notice and section 148A(d) order were issued by the JAO instead of the FAO. It reaffirmed that post-notification violations of the faceless scheme cannot be cured by participation or waiver.

Section 44AD Overrides Ad-Hoc 50% Profit Estimation

December 31, 2025 1062 Views 0 comment Print

ITAT Surat struck down a 50% turnover-based income estimation, applying Section 44AD to compute actual presumptive profit at 8%. Key takeaway: AO cannot inflate income without legal basis.

Accommodation Entry Purchases Confirmed for Lack of Proof

December 31, 2025 489 Views 0 comment Print

The case involved alleged bogus purchases backed only by invoices and bank payments. The Tribunal held that without confirmations, transport evidence, or delivery proof, such purchases cannot be treated as genuine.

Section 148 Notice Held Premature While Return Filing Window Open

December 31, 2025 708 Views 0 comment Print

The issue was whether reassessment could be initiated while the time to file a belated return was still open. The Tribunal held such reopening premature and void, as income cannot be said to have escaped assessment.

Borrowed Satisfaction Backfires: ITAT Ahmedabad Quashes 147 Reopenings Based on Dishman Group Search Inputs

December 31, 2025 732 Views 0 comment Print

ITAT held reassessment invalid as it was initiated merely on Insight Portal data and third-party statements without verification or application of mind.

JAO Can’t Reopen After Faceless Regime: ITAT Hyderabad Quashes s.148 Notices in 4 Appeals

December 31, 2025 495 Views 0 comment Print

The ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.

Reassessment Quashed for Non-Service of Notice: ITAT Delhi Strikes Down Jurisdictional Lapse

December 30, 2025 465 Views 0 comment Print

The issue was whether reassessment could survive when the mandatory section 148 no-tice was sent to an old address. The Tribunal held that improper service vitiates jurisdiction, rendering the entire reassessment void.

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