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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


Jurisdiction Fatal When 148 Notice Is in Name of Deceased Assessee

November 15, 2025 639 Views 0 comment Print

The Tribunal held that reopening notices and assessment orders under section 148 issued in the PAN of a deceased person are invalid. The ruling reinforces that reassessment proceedings require notices to be addressed to the correct taxpayer to maintain legal jurisdiction.

Addition Deleted Because Recorded Sales Cannot Be Taxed Again Under Section 68

November 15, 2025 690 Views 0 comment Print

The Tribunal held that once sales are accepted in audited books, they cannot be reclassified as unexplained cash credits. The addition of ₹41.74 lakh was struck down as it caused double taxation.

Reassessment Quashed for Using Section 147 Instead of Mandatory Section 153C

November 15, 2025 1176 Views 0 comment Print

The Tribunal ruled that reassessment under section 147 was invalid where the basis of information stemmed from a third-party search. It held that such cases must mandatorily proceed under section 153C. The key takeaway: search-linked data cannot justify a section 147 reopening.

60% Tax Disallowed Because Higher 115BBE Rate Applies Only From AY 2018-19

November 15, 2025 924 Views 0 comment Print

The Tribunal held that substantial bank deposits without filing a return provided adequate basis to reopen under section 147. Notice-service objections failed due to section 292BB, and the quantum issue was remanded for verification. The ruling confirms that prima facie material is sufficient for reassessment.

ITAT Holds Dismissal Invalid Where Assessee Not Heard on Section 249(4)(b) Requirement

November 15, 2025 489 Views 0 comment Print

The Tribunal held that the CIT(A) erred in dismissing the appeal solely for non-payment of advance tax without first seeking clarification from the assessee. Since the assessee acted under a bona fide belief that no advance tax was due, the ITAT restored the matter for fresh consideration. Key takeaway: procedural conditions under Section 249(4)(b) must be applied with fairness and opportunity of hearing.

Delay Condoned Because Temple Believed Income Was Exempt Under Section 10(23BBA)

November 15, 2025 414 Views 0 comment Print

 ITAT holds that the temples bona fide belief in statutory exemption justified a 607-day delay. Assessments and penalties are remanded for fresh review considering exemption applicability.

Chandigarh ITAT Quashes Reopening as Notice u/s 148 Issued by JAO Instead of FAO

November 15, 2025 498 Views 0 comment Print

ITAT Chandigarh held that a Section 148 notice issued by the Jurisdictional AO instead of Faceless AO violated statutory provisions, quashing the assessment for AY 2018-19.

Cancellation of registration u/s. 12AA without satisfying conditions u/s. 12AB(4)(ii) not justifiable

November 15, 2025 951 Views 0 comment Print

ITAT Hyderabad held that cancellation of registration granted to appellant-society u/s. 12AA of the Income Tax Act not justifiable since conditions precedent for cancellation of registration u/s. 12AB(4)(ii) of the Income Tax Act not satisfied.

Reassessment Notice Issued Beyond Surviving Time Held Invalid: Gujarat HC

November 14, 2025 1056 Views 0 comment Print

Gujarat HC quashed a Section 148 notice issued after permissible surviving time, ruling it time-barred under Supreme Court guidelines in Rajeev Bansal and Ashish Agarwal.

ITAT Delhi Sets Aside Reassessment Issued by Wrong Jurisdiction Officer

November 14, 2025 765 Views 0 comment Print

The ITAT Delhi annulled a reassessment after finding that the notice under Section 148 was issued by an officer without jurisdiction, rendering the entire proceeding invalid in law.

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