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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 309 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 726 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 297 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 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 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


Bogus Purchase Disallowance Limited to 6% Due to Genuine Sales

December 4, 2025 615 Views 0 comment Print

The Tribunal held that once sales are accepted and basic supporting documents exist, only the profit element in alleged bogus purchases can be taxed. It upheld a 6% GP addition and rejected the Revenue’s demand for 100% disallowance.

ITAT Orders Fresh Hearing After Non-Speaking CIT(A) Order in Reopening Case

December 4, 2025 315 Views 0 comment Print

The order was remanded after ITAT found the CIT(A) overlooked core issues including validity of belated 148 return, applicability of 153C, and cross-examination rights.

Tribunal Deletes ₹2.14 Crore Addition Due to Invalid Pre-Notification NFAC Action

December 4, 2025 1209 Views 0 comment Print

ITAT Kolkata quashed a reassessment order, holding that NFAC had no jurisdiction before the formal notification of Section 151A. The ₹2.14 crore addition was deleted, highlighting that faceless assessments cannot be retroactively enforced.

Bombay HC quashes Income Tax Notices Due to Approved Resolution Plan

December 4, 2025 753 Views 0 comment Print

The Court ruled that once a resolution plan is approved, prior tax liabilities are extinguished. Notices issued under Sections 148 and 142(1) for periods before approval were therefore invalid.

Tax Notice Quashed Because Claims Extinguished After Resolution Plan

December 4, 2025 579 Views 0 comment Print

The Court held that tax proceedings cannot continue for periods covered by an approved resolution plan. It ruled that past claims stood extinguished, leading to the quashing of the Section 148 notice.

Reassessment Notices Quashed for Lack of Jurisdiction Post-Faceless Scheme

December 4, 2025 924 Views 0 comment Print

The Court ruled that reassessment notices issued by the JAO after 29 March 2022 were without jurisdiction. The proceedings and related orders were struck down.

Prior approval u/s. 153D vitiated as granted without application of mind

December 4, 2025 366 Views 0 comment Print

Bombay High Court held that grant of approval under section 153D of the Income Tax Act cannot be merely a ritualistic formality. Thus, proceedings u/s. 153A, based on approval u/s. 153D granted without application of mind, is vitiated.

₹115 Cr Penny stock & Bogus loan Reassessment Quashed for Time-Barred Section 148 Notice

December 4, 2025 5562 Views 0 comment Print

ITAT Ahmedabad ruled that a notice under section 148 issued beyond the statutory period is invalid, quashing a ₹115 crore reassessment of a share-trading company. The Tribunal emphasized adherence to “surviving time” limits, making the reassessment void.

Section 148 Notice Without Jurisdiction Renders 263 Unsustainable

December 3, 2025 777 Views 0 comment Print

ITAT Ahmedabad held that a section 263 revision cannot proceed if the AO issuing section 148 notice lacks territorial jurisdiction, emphasizing the need to first decide jurisdictional validity.

193-Day Delay Condoned: ITAT Says Don’t Deny Merits to Rural Assessee

December 3, 2025 468 Views 0 comment Print

The Tribunal allowed a 193-day delayed appeal, emphasizing that non-deliberate delay should not bar hearing on merits. The assessee can now present his case and have the appeal adjudicated substantively.

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