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Section 148

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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 Quashed as Original Reason for 147 Fails – No Other Additions Can Survive

December 1, 2025 618 Views 0 comment Print

Rakesh Arora Vs ITO (ITAT Delhi) When the Reason Falls, the Case Falls: Rs. 3.14 Cr Trigger Proves False — ITAT Delhi Quashes Whole 147 The reassessment for AY 2012–13 was triggered solely on the allegation that the assessee had received accommodation entries of ₹3,14,16,000 from M/s Shreyas International. However, at the time of completing […]

JAO cannot issue Section 148 notices when faceless mechanism applies: AP HC

December 1, 2025 954 Views 0 comment Print

Andhra Pradesh High Court held that notices issued under Sections 148-A and 148 outside the faceless assessment scheme are illegal, emphasizing strict compliance with Section 151(A) and E-Assessment Scheme, 2022.

Revision Fails: PCIT Cannot Invoke 263 Without Making the Very Enquiry He Says AO Missed

December 1, 2025 306 Views 0 comment Print

The Tribunal held that Section 263 cannot be invoked when the PCIT himself does not conduct the verification he insists was missing. It reaffirms that revision requires demonstrated lack of inquiry, not assumptions.

Under-Reporting Penalty- AO Didn’t Decide Form 68 in Time: ITAT Deletes 270A Penalty

December 1, 2025 1395 Views 0 comment Print

The Tribunal held that the assessee cannot suffer due to the AO’s inaction under section 270AA(4), directing grant of immunity and cancelling the 270A penalty.

Reassessment Quashed: Penny-Stock Gains Fully Disclosed, No Evidence of Bogus Deals

December 1, 2025 828 Views 0 comment Print

The Tribunal ruled that additions based on third-party search without giving the assessee a chance to examine evidence violated natural justice, deleting ₹2.04 Cr and ₹64.11 Lakh for AY 2018-19 & 2019-20.

ITAT Hyderabad Deletes ₹17.55 Lakh Penalty: No Under-Reporting in Accepted 148 Return

December 1, 2025 666 Views 0 comment Print

The Tribunal held that the assessee’s delayed filing was bona fide due to disputes and legal ambiguities, and the declared income was fully accepted. No penalty under Section 270A was warranted.

Reassessment Quashed for Being Time-Barred: ITAT Holds 148 Notice Beyond Six-Year Limit

December 1, 2025 1353 Views 0 comment Print

Tribunal ruled that a 148 notice issued on 03.04.2022 for AY 2015-16 violated Section 149(1)(b)’s six-year limitation, rendering entire reassessment void. The is that notices issued after 31.03.2022 for AY 2015-16 are invalid.

Delhi ITAT Quashes Reopening Based on Mere Audit Objection: No New Material to Invoke Section 147

December 1, 2025 420 Views 0 comment Print

The Delhi ITAT held that reopening an assessment based solely on audit objections, without fresh material, is invalid. The tribunal emphasized that reassessment cannot be used for a mere change of opinion

Non-Application of Mind Invalidates Section 148A & 148 Notices: SC Upholds HC Decision

December 1, 2025 1389 Views 0 comment Print

Court held that reopening was invalid because officer ignored that depreciation on goodwill had already been accepted in earlier scrutiny assessments. It ruled that reassessment cannot be based solely on audit objections without independent evaluation.

Income Tax Reassessment Notice Invalid as AO Relied Only on Faulty Audit Objection

December 1, 2025 471 Views 0 comment Print

The Court ruled that reassessment could not be initiated based on audit objections containing factual errors and overlooking prior accepted depreciation. The decision underscores that reopening must be based on proper evaluation of facts, not mere audit remarks.

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