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Section 148

Latest Articles


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 306 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 720 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 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


Reassessment Quashed as Notice Uploaded After Limitation Due to Portal Glitch

November 27, 2025 585 Views 0 comment Print

The Court held that a reassessment notice generated on time but uploaded the next day is time-barred. Proceedings were set aside because despatch, not generation, determines the date of issuance.

Loose Excel Sheet With Wrong Seller Name Can’t Justify On-Money Addition

November 27, 2025 3708 Views 0 comment Print

Additions for alleged on-money payments were disallowed because the evidence relied on by authorities contained errors and lacked authenticity. The decision highlights the need for corroborated, primary evidence in tax proceedings.

Reassessment u/s. 147 based on information without application of mind is bad-in-law

November 27, 2025 708 Views 0 comment Print

ITAT Delhi held that reopening of assessment under section 147 of the Income Tax Act, solely on the basis of information received, without application of mind is bad-in-law and liable to be quashed. Accordingly, appeal of revenue dismissed.

Matching Principle Not applies to Cash Accounting – Section 36(1)(iii) Disallowance Deleted

November 27, 2025 327 Views 0 comment Print

The Madras High Court held that an investment company’s interest disallowance under Section 36(1)(iii) was invalid as it followed a cash system of accounting. The Tribunal’s deletion of the addition was upheld, confirming that matching principles are not applicable under cash-based accounting.

Entire 148A and 147 Proceedings Set Aside for Being Time-Barred

November 27, 2025 699 Views 0 comment Print

The ITAT quashed the entire reassessment proceedings for AY 2015-16, observing that the foundational notice was issued after the permissible date. The ruling underscores that procedural timelines under TOLA cannot be extended retroactively. Subsequent orders based on the invalid notice were held without jurisdiction.

Service of notice was mandatory before Income Tax Reassessment therefore, penalty u/s 271(1)(b) was quashed

November 27, 2025 495 Views 0 comment Print

Since valid service of notice was a mandatory jurisdictional requirement before initiating reassessment proceedings, therefore, purported notices issued under Section 148 including reassessment proceedings under

Share Premium Addition Quashed; DCF Valuation Cannot Be Replaced Without Specific Errors

November 27, 2025 396 Views 0 comment Print

Tribunal held that AO did not establish any defect in identity, genuineness, or creditworthiness of share subscribers. Addition under Section 68 was deleted.

Income Tax Assessment Set Aside for Violating Seven-Day Notice Requirement

November 27, 2025 1164 Views 0 comment Print

The Court held that the show cause notice provided less than seven days to respond, contrary to the prescribed procedure. The assessment and related notices were set aside and the matter remanded for reconsideration.

Reassessment Quashed: JAO Cannot Issue Section 148 Notice After Faceless Regime

November 27, 2025 1215 Views 0 comment Print

The High Court held that reassessment notices issued by the jurisdictional officer after the faceless regime came into force were without authority. All related proceedings were quashed, and the ITAT appeal was directed to be closed as infructuous.

SC Applies Rajeev Bansal Ruling to Revenue’s SLPs on Reassessment

November 27, 2025 672 Views 0 comment Print

SC disposes of Revenue SLPs; TOLA applies but reassessment timelines remain strictly enforced.

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