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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 336 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


Section 148 Notice Quashed for Vague Reasons & Lack of Supporting Material: ITAT Pune

Income Tax : ITAT Pune quashed a Section 148 notice based on vague information and directed deletion of a ₹51.35 lakh addition for lack of su...

July 8, 2026 57 Views 0 comment Print

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 351 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 885 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 306 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


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 5988 Views 0 comment Print


AO’s Suspicion Not Enough: ITAT Deletes Section 68 ‘Accommodation Entry’

November 28, 2025 567 Views 0 comment Print

The ITAT dismissed Revenue’s Section 68 additions, holding that the assessee proved the identity, creditworthiness, and genuineness of lenders. AO’s reliance solely on search statements was rejected.

JAO and FAO Have Concurrent Power to Issue Reassessment Notices: Delhi HC

November 28, 2025 1803 Views 0 comment Print

Delhi High Court ruled that both JAO and FAO have concurrent jurisdiction to issue reassessment notices under Sections 148/148A, aligning with TKS Builders precedent.

Non-Speaking Order Struck Down – ITAT Sends Capital Gain Appeal Back to CIT(A)

November 28, 2025 234 Views 0 comment Print

The assessee’s claim of ₹98.4 lakh as selling expenses on property sale was disallowed by AO and upheld by CIT(A) without proper reasoning. ITAT remanded the case to ensure a detailed, reasoned examination of the submissions on merits.

Section 44AD on Govt Charges? ITAT Pune Remands Stamp Duty Facilitator Case

November 28, 2025 270 Views 0 comment Print

The ITAT Pune held that applying presumptive taxation under Section 44AD to government-collected stamp duty and registration charges was unjustified. The case was remanded for fresh examination, considering subsequent years where identical transactions were accepted without additions.

TOLA Can’t Extend Section 148 Timeline: Rajkot ITAT Quashes Reopening

November 28, 2025 879 Views 0 comment Print

The Tribunal rejected the Revenue’s argument that TOLA extended the time for issuing notice, holding that for A.Y. 2015-16 the limitation expired on 31.03.2019. Consequently, the 21.04.2021 notice lacked legal authority. Key takeaway: TOLA does not revive time-barred assessments.

JAO-Issued Reassessment Notices Quashed for Violating Faceless Scheme

November 28, 2025 1278 Views 0 comment Print

The Telangana High Court ruled that Section 148 notices for central charge cases must follow the faceless procedure under the Finance Act, 2021, quashing JAO-issued notices.

Exemption Under Section 54F Allowed for Multiple Flats by Madras HC

November 28, 2025 1308 Views 0 comment Print

The Madras High Court ruled that Section 54F of the Income Tax Act can cover multiple residential units purchased from capital gains, reversing the ITAT’s single-flat restriction.

No Firm, No Assessment: ITAT Mumbai Strikes Down 147 on Dissolved Partnership

November 28, 2025 483 Views 0 comment Print

The Tribunal concluded that section 189 is only a machinery provision and cannot be invoked to assess alleged income arising long after a firm has ceased to exist. Since no evidence showed any business activity post-2012, the reopening for AY 2017-18 was invalid. The order quashing the reassessment also nullified the related addition and penalty.

No Section 270A Penalty When Cess Claim Made in Good Faith and Withdrawn Post-Amendment

November 28, 2025 1209 Views 0 comment Print

The Tribunal ruled that a cess deduction claim based on favourable jurisprudence cannot trigger penalty. Compliance with Section 155(18), including timely Form 69 filing, protected the assessee from under-reporting allegations.

Assessment Reopening Quashed Due to Defective Reasons and Roving Inquiry

November 28, 2025 1164 Views 0 comment Print

ITAT held that reassessment notices under sections 147/148 were invalid as the reasons were vague and lacked tangible evidence. Reopening cannot be used merely to verify or scrutinize transactions without proper justification.

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