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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


Reopening Collapses, All Other Additions Fall: ITAT Delhi Dismisses Revenue’s Appeal

December 30, 2025 552 Views 0 comment Print

The issue was whether additions could survive when the sole reason for reopening was not challenged. The ITAT held that without a valid reopening foundation, no other additions are sustainable.

CSR Grants Are Tied-Up Funds, Not Free Income of Charitable Trust

December 30, 2025 561 Views 0 comment Print

The Tribunal held that CSR contributions received with strict donor directions and refund obligations may constitute tied-up grants rather than freely available income. Such funds require factual examination before taxing them under section 11.

Past U/s 80-IA Relief Doesn’t Guarantee Deduction for New Projects

December 30, 2025 360 Views 0 comment Print

The Tribunal held that deduction under section 80-IA cannot be allowed mechanically based on past relief. Each infrastructure project must be independently examined to determine whether it qualifies as development or is merely a works contract.

Section 153C Notice Invalid for 22-Month Delay in Recording Satisfaction

December 30, 2025 624 Views 0 comment Print

The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.

Reassessment dropped as tax paid on consolidated profit and hence no escapement of income

December 30, 2025 666 Views 0 comment Print

ITAT Rajkot held that there is no escapement of income or loss of revenue since tax paid on the basis of consolidated profit of both the partnership firm and hence reassessment proceedings are not sustainable. Accordingly, appeal of revenue is dismissed.

Employee Not Liable for Employer’s Business Expenses

December 30, 2025 282 Views 0 comment Print

The Tribunal deleted additions holding that expenses incurred on behalf of an employer company and recorded in its books cannot be assessed in the employee’s personal assessment.

No 143(2) Notice Means No Valid Assessment, Rules ITAT

December 30, 2025 678 Views 0 comment Print

The Tribunal held that an assessment completed without issuing notice under section 143(2) is void ab initio. Non-participation by the assessee cannot cure this jurisdictional defect.

Section 147 Reopening Can’t Be Based Only on Cash Deposit Alerts

December 30, 2025 582 Views 0 comment Print

The Tribunal quashed reassessment where the Assessing Officer invoked section 147 without examining books of account or correlating bank deposits with returned income.

Section 50C Not Applicable to Transfer of Life Interest in Property

December 30, 2025 966 Views 0 comment Print

The Tribunal held that assignment of a life interest under a trust does not amount to transfer of land or building. Since only a limited, determinable right was transferred, Section 50C could not be invoked.

Wrong Authority Approval Invalidates Reopening Beyond Three Years

December 30, 2025 585 Views 0 comment Print

The Tribunal ruled that where more than three years have elapsed, sanction must come from the Principal Chief Commissioner. Approval by the Principal Commissioner renders the reassessment void ab initio.

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