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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


Mandatory approval required from Higher Authority for issuing notice u/s 148 after expiry of 3-Year Limitation

November 13, 2025 1755 Views 0 comment Print

Reassessment proceedings initiated without obtaining prior approval from the appropriate “specified authority” under Section 151(ii) such as the Principal Chief Commissioner of Income Tax or the Principal Director General were invalid.

Assessment Order Void When Issued to Non-Existent Merged Entity: ITAT Mumbai

November 12, 2025 780 Views 0 comment Print

ITAT Mumbai ruled that once the Assessing Officer is aware of a merger, assessment in the name of the amalgamating company is invalid and without jurisdiction.

Madras HC Upheld Ex Parte Reassessment Order Due to Non-Response to Notice

November 12, 2025 501 Views 0 comment Print

The Madras High Court upheld a reassessment order passed under Section 144 after the taxpayer failed to respond to Section 148 notices. The Court found no reason to interfere but permitted an appeal within 30 days.

Only Profit on Bogus Purchases Taxable – Full Disallowance Unjustified: ITAT Mumbai

November 12, 2025 741 Views 0 comment Print

ITAT Mumbai held that doubting goods transportation alone cannot justify full disallowance, restricting the addition to 11.54% GP on ₹32.75 lakh purchases.

Mechanical Approval Under Repealed Section Invalidates Reopening: ITAT Delhi

November 12, 2025 459 Views 0 comment Print

ITAT Delhi invalidated a reassessment under Sections 144/147, citing mechanical approval by authorities and incorrect statutory references. The ruling reinforces that higher authorities must apply proper legal mind when granting sanction under Section 151.

Bogus Purchase: ITAT Quashes 271(1)(c) Penalty as Specific Limb not Mentioned

November 12, 2025 897 Views 0 comment Print

 ITAT Mumbai deleted a penalty under Section 271(1)(c) because the notice failed to specify whether it targeted concealment of income or inaccurate particulars. The ruling highlights the need for clarity in issuing tax penalties.

Extrapolation cannot be done to assume income without any cogent material

November 12, 2025 732 Views 0 comment Print

ITAT Mumbai held that no extrapolation can be done on estimation basis in absence of any incriminating material. Accordingly, addition rightly deleted by CIT(A). Thus, order of CIT(A) upheld and appeal of revenue dismissed to that extent.

ITAT Delhi Remands ₹61 Lakh Property Addition – Additional Evidence Admitted Under Rule 29

November 12, 2025 273 Views 0 comment Print

ITAT Delhi remitted a case where CIT(A) upheld additions without examining available evidence. The ruling reinforces that authorities must fully consider documents and explanations before confirming unexplained investments.

Identity Proved, Genuineness Unclear: ITAT Remands ₹50 Lakh Loan Case to AO

November 12, 2025 657 Views 0 comment Print

The ITAT Mumbai remanded a ₹50 lakh addition case after finding that a business loan was omitted from audited accounts and required further verification.

ITAT Upholds 5% Income Estimation on Accommodation Entry Transactions

November 11, 2025 609 Views 0 comment Print

The tribunal dismissed both assessee and Revenue appeals, confirming that income from accommodation entries can be estimated at 5% of credit entries in the bank. The ruling clarifies that when commissions are claimed on transactions without actual goods delivery, a reasonable percentage can be applied to determine taxable income.

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