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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 333 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 786 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 300 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 291 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 231 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 58947 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


No addition based on Unsigned Draft Agreement Found on Third Party’s Hard Disk Without Corroboration

December 25, 2025 771 Views 0 comment Print

The Tribunal ruled that an unsigned and undated draft agreement seized from a third party cannot justify an addition for unexplained investment without corroborative evidence.

Section 115BBE Not Applicable to Business Receipts; Only Profit on Cash Deposits Taxable

December 25, 2025 735 Views 0 comment Print

The Tribunal held that cash deposits representing trading receipts cannot be taxed in full as unexplained income. Only the estimated profit portion was directed to be assessed.

Reassessment Quashed Because Notice Was Issued Beyond Limitation Period

December 25, 2025 651 Views 0 comment Print

The Tribunal held that a notice issued after three years was time-barred under section 149. Since the ₹50 lakh exception did not apply, the reassessment was invalid.

Notice Under Section 148 Invalid When Tax Issue Is Concluded in Earlier Years: ITAT Delhi

December 25, 2025 489 Views 0 comment Print

The Tribunal held that reopening an assessment on a recurring issue already decided in favour of the taxpayer by the High Court is invalid. Pending appeal before the Supreme Court cannot justify reassessment.

Documented FDI Through Banking Channels Escapes Section 69

December 24, 2025 393 Views 0 comment Print

The dispute involved taxing a foreign investment as unexplained income. The Tribunal clarified that Section 69 applies only where investments are not recorded in books or the source remains unexplained.

Section 197 Certificate Quashed Because DAPE Finding Was Overturned

December 24, 2025 411 Views 0 comment Print

The Delhi High Court held that a withholding tax certificate cannot stand once the ITAT sets aside the finding of a dependent agent PE. Since the Revenue relied solely on quashed assessment orders, the 8.75% TDS was invalid.

Reassessment u/s. 147 after expiry of four years tenable since all material facts not disclosed

December 23, 2025 450 Views 0 comment Print

Madras High Court held that reassessment under section 147 of the Income Tax Act after expiry of four years is sustainable in law since assessee has failed to set out truly and fully all the material facts.

Wrong Authority Approval Voids Reassessment Beyond 3 Years

December 23, 2025 768 Views 0 comment Print

The Tribunal held that approval by an incompetent authority under Section 151(ii) invalidates a reassessment issued after three years. The notice and consequential order were declared void for lack of jurisdiction.

Fair Hearing Mandatory for Section 251 Income Enhancement: ITAT Amritsar

December 23, 2025 318 Views 0 comment Print

ITAT ruled that enhancement of income under section 251 without giving the assessee a proper hearing is invalid. The appeals were remanded to CIT(A) for fresh adjudication.

Belated U/s 148 Return Costs Assessee: 1% NP Estimation Upheld

December 23, 2025 237 Views 0 comment Print

The tribunal held that non-filing of return within the due date disentitled the assessee from deduction under section 80P due to section 80AC. Consequently, lower profit claims based on accounts were rejected.

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