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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 by JAO Quashed, Faceless Assessment Applies from Notice Stage

November 22, 2025 5886 Views 0 comment Print

Punjab and Haryana High Court held that a Section 148 notice issued by a Jurisdictional Assessing Officer after the faceless assessment scheme is invalid. The notice contravened Section 151A and the 2022 e-Assessment scheme. The court quashed the notice with directions to follow statutory faceless procedure.

Reassessment Quashed u/s 151 for Wrong Authority Beyond 3 Years

November 21, 2025 486 Views 0 comment Print

ITAT Delhi held that obtaining sanction u/s 151 from PCIT instead of PCCIT for reopening beyond 3 years invalidates reassessment. Jurisdictional defect renders entire proceedings void.

Cash Deposit Linked to Property Sale: ITAT Sends Matter Back for Fresh Examination

November 21, 2025 654 Views 0 comment Print

The Tribunal set aside the ex parte confirmation of a cash-deposit addition and directed fresh examination after the assessee produced sale-related documents. The key takeaway is that additions under section 69 require proper verification of evidence.

Reassessment Quashed – Section 151 Approval Held Mechanical; No Application of Mind by PCIT

November 21, 2025 654 Views 0 comment Print

The Tribunal held that reopening was invalid as the sanctioning authority recorded only a one-word approval. Key takeaway: Mechanical approval without reasoning vitiates jurisdiction under Section 147.

Quashed Reassessment: Borrowed Info & Sec 151 Approval Invalid

November 21, 2025 327 Views 0 comment Print

Reopening notice under Section 148 was held invalid as the AO ignored co-purchasers’ contributions and granted mechanical approval under Section 151 without application of mind. The Tribunal ruled the reassessment and associated additions null and void.

ITAT Deletes Section 69A Addition for Bank Deposits from Liquor Receivables

November 21, 2025 504 Views 0 comment Print

The Tribunal held that deposits in the assessee’s bank account represented genuine receivables from a previously acknowledged liquor business. Since the source was documented and undisputed, the Sec.69A addition of Rs.12.21 lakhs was deleted.

ITAT Quashes Reassessment for Penny Stock Loss Lacking Direct Nexus

November 21, 2025 3645 Views 0 comment Print

ITAT Ahmedabad held that reassessment under Section 147 cannot be based on vague or unverified information; specific transactions must be identified to justify additions.

ITAT Quashes Section 148 Notice Beyond 3 Years for Wrong Section 151 Approval

November 21, 2025 609 Views 0 comment Print

The Tribunal found that sanction must come from the Principal Chief Commissioner when reopening is beyond the three-year period prescribed by the amended law. Because the approval was taken from the Pr. CIT, the reassessment lacked jurisdiction and was invalidated.

Bombay HC Quashes Reassessment as Section 148 Notice Issued to Non-Existent Entity

November 20, 2025 945 Views 0 comment Print

The Court held that a reassessment notice issued to an entity that had ceased to exist after conversion into an LLP was invalid. The ruling confirms that tax proceedings cannot continue against non-existent entities.

Unexplained investment addition relying solely upon unverified excel sheet and loose sheet cannot be sustained

November 20, 2025 849 Views 0 comment Print

ITAT Mumbai held that addition towards unexplained investment u/s. 69A/69B relying solely upon unverified excel sheet, loose sheet and uncorroborated statements, has traversed beyond the permissible confines of evidentiary inference. Accordingly, addition is liable to be deleted.

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