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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 14058 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 2823 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 1053 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

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 282 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 657 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 291 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 285 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 228 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 58938 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


ITAT Deletes Capital Gains Addition: Agreement to Sell Alone Does Not Amount to Transfer

June 15, 2026 354 Views 0 comment Print

ITAT deleted the addition after finding that neither possession nor ownership had passed during the relevant assessment year. The decision emphasizes that actual transfer, not mere intention to sell, determines taxability.

Bogus Political Donation Claim Fails: ITAT Upholds Denial of Section 80GGC Deduction

June 15, 2026 2754 Views 0 comment Print

ITAT held that proving the mode of payment is not enough to secure deduction for political contributions where evidence points to a bogus donation scheme. Taxpayers must establish the authenticity of the entire transaction.

Faceless Reassessment Amounting to Best Judgment Assessment Can Be Remitted by CIT(A)

June 14, 2026 378 Views 0 comment Print

The Delhi ITAT held that repeated non-compliance with statutory notices transformed the reassessment into a best judgment assessment in substance. Consequently, the CIT(A) was justified in remanding the matter to the Assessing Officer for fresh adjudication.

AO Failed to Record Mandatory Conditions for Reopening: ITAT Deletes ₹13.10 Crore Share Capital Addition

June 14, 2026 225 Views 0 comment Print

The Delhi ITAT held that reassessment notices issued beyond four years were invalid as the Assessing Officer failed to record the assessee’s alleged failure to make full and true disclosure. The addition relating to ₹13.10 crore share application money was consequently set aside.

Income Tax Notice Invalid for Failure to Follow Faceless Assessment Procedure

June 13, 2026 447 Views 1 comment Print

The High Court held that reassessment notices issued physically by jurisdictional officers instead of faceless authorities violate Section 151A. The ruling sets aside non-compliant notices while tying the final outcome to pending Supreme Court decisions.

Telangana HC Quashes Reassessment Notices Due to Jurisdictional Defect in Proceedings

June 13, 2026 297 Views 0 comment Print

The High Court set aside notices issued under Sections 148A and consequential reassessment orders after holding that the proceedings suffered from jurisdictional infirmities. The relief, however, remains subject to the Supreme Court’s decision in the pending SLP.

ITAT Quashes Reassessment: Approval from PCIT Instead of PCCIT Proves Fatal

June 13, 2026 381 Views 0 comment Print

The Tribunal held that notices issued after three years from the relevant assessment year require prior approval from the PCCIT. Approval from the PCIT in such cases renders the reassessment notice legally unsustainable.

Mumbai ITAT: Reassessment Must Tax Real Income, Not Duplicate Salary Entries; CCM Addition Deleted for Want of Evidence

June 13, 2026 270 Views 0 comment Print

Mumbai ITAT held that additions under Section 69 cannot survive where transactions are reflected in broker records and the source of funds is explained. Mere Client Code Modification information, without supporting evidence of tax evasion, is insufficient for making additions.

Interest Disallowance Deleted as Own Funds Exceeded Advances: ITAT Pune

June 13, 2026 168 Views 0 comment Print

The Tribunal ruled that proportionate interest disallowance under Section 36(1)(iii) cannot be sustained when the assessee has adequate reserves and interest-free funds to cover the advances. The Revenue failed to rebut the presumption recognized by higher courts.

Bombay HC Quashes Reassessment as Broken Period Interest Deduction Was Already Settled by SC

June 13, 2026 276 Views 0 comment Print

The Bombay High Court held that reassessment proceedings could not be initiated on the issue of broken period interest when the legal position had already been settled by binding precedents. The Court quashed the notices issued under Sections 148A and 148.

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