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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 333 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 786 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 300 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 231 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


Addition Deleted Because Ownership of Cash Cannot Be Presumed on Suspicion

December 2, 2025 840 Views 0 comment Print

ITAT held that Section 69 cannot apply when the assessee is not proved to own the cash. Unrebutted affidavits established the source, and mere suspicion cannot justify an addition.

Benami Allegation Entangled – Double Taxing Same Investment Impermissible

December 2, 2025 474 Views 0 comment Print

Tribunal held that an investment already assessed substantively in another person’s hands cannot again be taxed under Section 69. The case was remanded to avoid double taxation and ensure consistent adjudication.

Section 147 Bogus Purchase Addition Deleted; Tribunal Upholds GST Records

December 2, 2025 498 Views 0 comment Print

Tribunal held that a reassessment cannot be triggered solely on another person’s search statement. With no evidence against the assessee, the 147 proceedings and bogus-purchase addition were struck down.

Reopening Dies Twice: ITAT Hyderabad Quashes 148 Notice for Limitation Wrong Approval

December 1, 2025 1614 Views 0 comment Print

The Tribunal held that the reassessment was issued 45 days beyond the maximum permissible period under Rajeev Bansal (SC), making the 148 notice invalid. Applying the deemed-notice framework of Ashish Agarwal, it ruled that the AO had “zero surviving days” to act. The reassessment was quashed for being issued after the statutory outer limit.

ITAT Rajkot: Wrong Sanction & Late 148 Notice Void Reassessment

December 1, 2025 774 Views 0 comment Print

Reassessment notice issued beyond statutory time limit under Section 148 was invalid; Tribunal quashed proceedings for A.Y. 2013-14, emphasizing procedural compliance.

Portal Date vs Notice Date: ITAT Orders Fresh Hearing on Legality of Reassessment Notice

December 1, 2025 483 Views 0 comment Print

The Tribunal found that the Section 148 notice appeared on the portal after 31.03.2021, raising doubts about its validity. The matter was restored to CIT(A)/NFAC for fresh consideration, allowing the assessee to submit explanations. The ruling underscores strict compliance with notice issuance requirements under Section 148.

Reopening Quashed as Original Reason for 147 Fails – No Other Additions Can Survive

December 1, 2025 672 Views 0 comment Print

Rakesh Arora Vs ITO (ITAT Delhi) When the Reason Falls, the Case Falls: Rs. 3.14 Cr Trigger Proves False — ITAT Delhi Quashes Whole 147 The reassessment for AY 2012–13 was triggered solely on the allegation that the assessee had received accommodation entries of ₹3,14,16,000 from M/s Shreyas International. However, at the time of completing […]

JAO cannot issue Section 148 notices when faceless mechanism applies: AP HC

December 1, 2025 1005 Views 0 comment Print

Andhra Pradesh High Court held that notices issued under Sections 148-A and 148 outside the faceless assessment scheme are illegal, emphasizing strict compliance with Section 151(A) and E-Assessment Scheme, 2022.

Revision Fails: PCIT Cannot Invoke 263 Without Making the Very Enquiry He Says AO Missed

December 1, 2025 327 Views 0 comment Print

The Tribunal held that Section 263 cannot be invoked when the PCIT himself does not conduct the verification he insists was missing. It reaffirms that revision requires demonstrated lack of inquiry, not assumptions.

Under-Reporting Penalty- AO Didn’t Decide Form 68 in Time: ITAT Deletes 270A Penalty

December 1, 2025 1536 Views 0 comment Print

The Tribunal held that the assessee cannot suffer due to the AO’s inaction under section 270AA(4), directing grant of immunity and cancelling the 270A penalty.

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