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Section 148

Latest Articles


Bombay HC Invalidates Reassessment Notice for AY 2015-16: Lack of DIN & Jurisdictional Issue

Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...

July 6, 2024 834 Views 0 comment Print

Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Wrong SFT Reporting may invite Notice U/s 148A of Income Tax Act, 1961

Income Tax : Discover the consequences of incorrect SFT reporting triggering U/s 148A notices under the Income Tax Act, 1961. Learn from a deta...

February 27, 2024 3456 Views 0 comment Print

Proposed Penal Provision For Non Registration of Machines In GST

Goods and Services Tax : Explore the proposed penalties in Finance Bill 2024 for non-registration of machines under GST. Analysis of Section 122A and the i...

February 13, 2024 5004 Views 0 comment Print


Latest News


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 6453 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 6936 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 12900 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 41382 Views 2 comments Print

Recall section 148 issued notice under old law after 31.03.2021

Income Tax : DTPA has made a representation to Finance Minister, Smt. Nirmala Sitharaman and requested for for recalling notices under section...

July 5, 2021 21189 Views 3 comments Print


Latest Judiciary


Reassessment cannot be based merely on suspicion or unverified information

Income Tax : Read the full text of the ITAT Kolkata order on Alosha Marketing Pvt Ltd Vs ACIT, discussing reopening of assessment under sec 147...

July 18, 2024 39 Views 0 comment Print

ITAT Upholds Section 56(2) Addition for Property Purchase Without Consideration

Income Tax : Read the detailed analysis of Indira Ramaiah Vs ITO case by ITAT Bangalore. ITAT upheld the addition of gift for undisclosed inves...

July 18, 2024 336 Views 0 comment Print

Assessment Order Passed after allowing only 2 Days to respond to SCN not Sustainable

Income Tax : In this case, Gudiyatham Muniraj Ashokkumaran challenged an assessment order, citing breach of natural justice principles due to i...

July 18, 2024 270 Views 0 comment Print

Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 150 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 180 Views 0 comment Print


Latest Notifications


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 12480 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 3084 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 5337 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 2934 Views 0 comment Print

Carry out due verification before initiating Section 148/147 proceedings: CBDT

Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...

August 22, 2022 13359 Views 0 comment Print


Handling of non-responsive Income Tax cases for physical verification

March 12, 2021 7446 Views 0 comment Print

Compulsory/148/Set aside cases – where the assessee has not responded to the notices in last 30 days. However, the cases where emails are not present (cases without digital footprint) may not be marked as they would be handled by different procedure.

CBDT clarifies on potential cases for issue of Section 148 notice

March 12, 2021 25839 Views 0 comment Print

The ‘potential cases’ at Point no.1(iii) mean the cases flagged by the Directorate of Income-tax (Systems) subsequent to 04.03.2021. It is further clarified that the NMS cases flagged earlier will get subsumed in the new list.

Reassessment invalid if satisfaction for reopening recorded in mechanical manner

March 11, 2021 1941 Views 0 comment Print

Sungrow Impex Private Limited Vs ITO (ITAT Delhi) Conclusion: CIT had recorded his satisfaction for reopening of the assessment in a most mechanical manner without considering even the assessment records or the return of income filed by assessee and his satisfaction appeared to be in a ritualistic and formal rather than meaningful. Therefore, such approval […]

Income escaping assessment | Action to be taken | AY 2013-14 to 2017-18

March 9, 2021 19983 Views 0 comment Print

Which functionality is to be used for uploading the information in respect of cases where the income escaping assessment pertains to AYs 2013-14 to 2017-18 as mentioned in Para 2(a) of the aforementioned directions issued vide F.No.414/132/2018-IT(Inv.I)(Part I) dated 5th March, 2021?

Instructions for issue of Section 148 notice for Reassessment/Reopening

March 4, 2021 47217 Views 2 comments Print

CBDT directs that following categories of cases be considered as ‘potential cases’ for taking action u/s 148 of Act by 31.03.2021 for the A.Y 2013-14 to A.Y 2017-18 by Jurisdictional Assessing Officer

Addition for unexplained cash deposit by CIT(A) justified -ITAT Delhi

March 4, 2021 3789 Views 0 comment Print

Shri Praveen Garg Vs ITO  (ITAT Delhi) There is no dispute with regard to the legal proposition that the First Appellate Authority cannot consider new source of income. However, in the present case the A.O. reopened the assessment because it was found that there were cash deposits in several Bank accounts of the assessee which […]

HC quashes Section 148 Notice issued without prior administrative approval of PCIT

March 4, 2021 2565 Views 0 comment Print

According to Mr. Mahna, the administrative approval of Principal Chief Commissioner, Income Tax was obtained by the Assistant Commissioner, Income Tax only on 30.03.2018, i.e., after the issuance of the notice under Section 148 of the Act.

No Reopening On Borrowed Satisfaction Without Bringing Tangible Material on Record

February 23, 2021 1842 Views 0 comment Print

Luxe Trading And Holding (India) Pvt. Ltd. Vs ITO (ITAT Delhi) From a perusal of the reasons, it is seen that the notice u/s. 148 of the Act has been issued mechanically without application of mind and the satisfaction by the Assessing Officer is only the borrowed satisfaction of the Investigation Wing. The Assessing Officer, […]

No Change of Opinion if facts related to deemed consideration U/s. 50C been overlooked

February 19, 2021 981 Views 0 comment Print

Rakesh Ambalal Patel Vs ITO (ITAT Ahmedabad) We have perused the assessment order and the order of the CIT(A) as well as the materials placed on record and referred to in terms of Rule 18(6) of the Income Tax (Appellate Tribunal) Rules, 1963. On perusal, we observe that at the time of original assessment proceedings, […]

No Reopening on Borrowed Satisfaction when view was already taken by AO

February 19, 2021 1506 Views 0 comment Print

Alliance Filaments Ltd Vs ACIT (Gujarat High Court) A plain reading of the reasons recorded revels that the Assessing Officer has solely relied on the information received from the Investigation Wing- Surat. We are of the view that, the Assessing Officer has not applied his independent mind while recording the reasons that the income has […]

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