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Section 148

Latest Articles


Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...

May 13, 2026 405 Views 0 comment Print

Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 759 Views 0 comment Print

Reassessment Invalid as AO Failed to Issue 143(2) Notice After Belated Return

Income Tax : ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143...

April 2, 2026 1140 Views 0 comment Print

Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 1866 Views 0 comment Print

Updated Return After Reassessment Notice Comes With Higher Tax Cost Because Additional 10% Levy Proposed

Income Tax : The Finance Bill 2026 proposes allowing taxpayers to file an Updated Return even after receiving a reassessment notice under Secti...

March 6, 2026 2373 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 2286 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 4404 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 6882 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 7494 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 13347 Views 0 comment Print


Latest Judiciary


ITAT Indore Sets Aside Ex Parte CIT(A) Order as Notices Were Sent to Wrong Email Address

Income Tax : ITAT Indore held that appellate order violated principles of natural justice after finding that key hearing notices were sent to a...

May 22, 2026 108 Views 0 comment Print

Section 148 Notice Invalid as It Was Issued by JAO Instead of FAO: Rajasthan HC

Income Tax : Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2...

May 22, 2026 333 Views 0 comment Print

Madras HC Quashes Section 148 Notices as They Were Issued by Jurisdictional AO

Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...

May 22, 2026 780 Views 0 comment Print

Reassessment Notices Invalid as Faceless Procedure Was Not Followed: Madras HC

Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...

May 22, 2026 699 Views 0 comment Print

Jharkhand HC Upholds Reassessment Proceedings as Finance Act 2026 Inserted Section 147A Retrospectively

Income Tax : The Jharkhand High Court held that retrospective insertion of Section 147A removed the jurisdictional challenge against reassessme...

May 22, 2026 195 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 1026 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 5832 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 57513 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 5898 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 5910 Views 0 comment Print


Bulk Sale Discount Valid: Reason Tax Authorities Cannot Force a ‘Uniform Price’ on Share Transactions

October 17, 2025 237 Views 0 comment Print

Delhi ITAT grants relief to Park View Automotive, deleting a ₹5.59 Cr. addition on share sale. The Tribunal held that an AO cannot arbitrarily substitute a genuine bulk sale price based merely on an Investigation Wing report or suspicion, emphasizing that concrete documentary evidence must be rebutted.

How to Address Key Income Tax Notices and Avoid Penalty?

October 17, 2025 786 Views 0 comment Print

Learn to address crucial Income Tax notices like 143(1), 143(2), 148, 139(9), and 245. Timely, informed action prevents penalties, best judgment assessment, and legal issues.

Time-Barred Notice, No Evidence, MAT Higher – ITAT Quashes Reopening & Wipes Out ₹25 Cr Addition

October 17, 2025 360 Views 0 comment Print

The Tribunal voided the reassessment, citing multiple legal failures: it was time-barred under the new law, the AO failed to share mandatory material, and the condition under Section 149(1)(b) requiring a proven asset/expenditure was not met. The ruling provides strong takeaways on the validity of new reassessment provisions.

ITAT Quashes 4 Years of Assessments: Mechanical Sanction and Vague Reasons Vitiate Jurisdiction

October 17, 2025 651 Views 0 comment Print

The Tribunal nullified four assessment years (AY 2013-14, 2014-15, 2018-19, 2021-22) due to serious legal defects, including unsigned/mechanical approvals and non-supply of mandatory sanction and underlying material. This ruling emphasizes that defective procedure is fatal to both reopening and regular assessment proceedings.

No Exempt Gain, Only Genuine Loss – ITAT Rejects Penny Stock Allegation Allows ₹26.13L Business Loss

October 17, 2025 375 Views 0 comment Print

The ITAT ruled that a claimed business loss on the sale of a scrip, allegedly part of a penny stock syndicate, was genuine and allowable. The ruling emphasized that transactions supported by complete documentation (contract notes, demat, bank statements) and where no tax-exempt capital gain was claimed cannot be disallowed merely based on a general modus operandi or third-party information.

No 143(2), No Jurisdiction- ITAT Quashes Penny Stock Reassessment Despite Non-Cooperation by Assessee

October 17, 2025 294 Views 0 comment Print

The ITAT held a reassessment under sections 144/147 void due to the absence of a mandatory 143(2) notice. Revenue’s claim that participation cures defects under 292BB was rejected, emphasizing strict compliance with statutory notice requirements.

Income Tax Jurisdiction Defect: ACIT Cannot Issue 148 Notice Below ITO’s Prescribed Monetary Limit

October 17, 2025 900 Views 0 comment Print

An assessment was quashed as the ACIT (a senior authority) issued the reassessment notice for an income below the Rs.15 Lakh limit, which was exclusively the ITO’s jurisdiction. The Tribunal affirmed that this jurisdictional defect is fatal and cannot be cured, following the Bombay High Court’s ruling.

Rectification, Assessment and Appeal under Income Act, 1961

October 17, 2025 12960 Views 0 comment Print

Understand the three core processes of Indian Income Tax: Rectification of mistakes (Sec 154), the four types of Assessment (Summary, Scrutiny, Best Judgment, and Reassessment), and the Appeal mechanism to CIT(A)/ITAT against adverse orders.

ITAT Deletes Addition on Alleged Shell Company Funds as AO Failed to Prove Transaction

October 17, 2025 540 Views 0 comment Print

The Kolkata ITAT allowed Winner Tradecom Pvt. Limited’s appeal, deleting a ₹15 lakh addition made under Section 68 for an alleged credit from a shell company.

Section 148 Reassessment Stayed Pending SC Verdict: HP HC

October 17, 2025 855 Views 0 comment Print

Himachal Pradesh High Court refuses to decide on the jurisdiction of Section 148 Income Tax notices for AY 2020-21 as a similar issue is pending before the Supreme Court; proceedings are stayed.

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