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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


Section 148 Notice Quashed for Breach of Faceless Reassessment Rules

November 29, 2025 2406 Views 0 comment Print

The Court set aside notices issued manually by the JAO, holding that reassessment and issuance of Section 148 notices must follow the mandatory faceless mechanism under Section 151A. The ruling reinforces that the JAO has no concurrent jurisdiction.

Reassessment Notice Issued on or after 1 April 2021 Must Follow Amended Section 148A  

November 29, 2025 9849 Views 0 comment Print

Aseem Sehgal Vs ITO (ITAT Delhi) The appeals concern assessment years 2015–16 to 2017–18 and arise from reassessment orders issued under Sections 147 and 144B of the Income-tax Act. The sole issue examined by the Tribunal is whether the Assessing Officer was justified in framing reassessment under the pre-April 2021 provisions despite issuing the notice […]

CIT(A) Dismissed Appeal for Non-Prosecution; ITAT Restores After Assessee Explains Missed Notice

November 28, 2025 249 Views 0 comment Print

The ITAT Pune remanded a case where the first appellate authority dismissed an appeal ex-parte.  taxpayers must be given a fair hearing before dismissal, reinforcing the principle of natural justice.

AO’s Suspicion Not Enough: ITAT Deletes Section 68 ‘Accommodation Entry’

November 28, 2025 510 Views 0 comment Print

The ITAT dismissed Revenue’s Section 68 additions, holding that the assessee proved the identity, creditworthiness, and genuineness of lenders. AO’s reliance solely on search statements was rejected.

JAO and FAO Have Concurrent Power to Issue Reassessment Notices: Delhi HC

November 28, 2025 1683 Views 0 comment Print

Delhi High Court ruled that both JAO and FAO have concurrent jurisdiction to issue reassessment notices under Sections 148/148A, aligning with TKS Builders precedent.

Non-Speaking Order Struck Down – ITAT Sends Capital Gain Appeal Back to CIT(A)

November 28, 2025 216 Views 0 comment Print

The assessee’s claim of ₹98.4 lakh as selling expenses on property sale was disallowed by AO and upheld by CIT(A) without proper reasoning. ITAT remanded the case to ensure a detailed, reasoned examination of the submissions on merits.

Section 44AD on Govt Charges? ITAT Pune Remands Stamp Duty Facilitator Case

November 28, 2025 234 Views 0 comment Print

The ITAT Pune held that applying presumptive taxation under Section 44AD to government-collected stamp duty and registration charges was unjustified. The case was remanded for fresh examination, considering subsequent years where identical transactions were accepted without additions.

TOLA Can’t Extend Section 148 Timeline: Rajkot ITAT Quashes Reopening

November 28, 2025 762 Views 0 comment Print

The Tribunal rejected the Revenue’s argument that TOLA extended the time for issuing notice, holding that for A.Y. 2015-16 the limitation expired on 31.03.2019. Consequently, the 21.04.2021 notice lacked legal authority. Key takeaway: TOLA does not revive time-barred assessments.

JAO-Issued Reassessment Notices Quashed for Violating Faceless Scheme

November 28, 2025 1224 Views 0 comment Print

The Telangana High Court ruled that Section 148 notices for central charge cases must follow the faceless procedure under the Finance Act, 2021, quashing JAO-issued notices.

Exemption Under Section 54F Allowed for Multiple Flats by Madras HC

November 28, 2025 1176 Views 0 comment Print

The Madras High Court ruled that Section 54F of the Income Tax Act can cover multiple residential units purchased from capital gains, reversing the ITAT’s single-flat restriction.

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