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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


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 345 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 837 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

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


Quashed Reassessment: Borrowed Info & Sec 151 Approval Invalid

November 21, 2025 372 Views 0 comment Print

Reopening notice under Section 148 was held invalid as the AO ignored co-purchasers’ contributions and granted mechanical approval under Section 151 without application of mind. The Tribunal ruled the reassessment and associated additions null and void.

ITAT Deletes Section 69A Addition for Bank Deposits from Liquor Receivables

November 21, 2025 588 Views 0 comment Print

The Tribunal held that deposits in the assessee’s bank account represented genuine receivables from a previously acknowledged liquor business. Since the source was documented and undisputed, the Sec.69A addition of Rs.12.21 lakhs was deleted.

ITAT Quashes Reassessment for Penny Stock Loss Lacking Direct Nexus

November 21, 2025 3696 Views 0 comment Print

ITAT Ahmedabad held that reassessment under Section 147 cannot be based on vague or unverified information; specific transactions must be identified to justify additions.

ITAT Quashes Section 148 Notice Beyond 3 Years for Wrong Section 151 Approval

November 21, 2025 675 Views 0 comment Print

The Tribunal found that sanction must come from the Principal Chief Commissioner when reopening is beyond the three-year period prescribed by the amended law. Because the approval was taken from the Pr. CIT, the reassessment lacked jurisdiction and was invalidated.

Bombay HC Quashes Reassessment as Section 148 Notice Issued to Non-Existent Entity

November 20, 2025 1047 Views 0 comment Print

The Court held that a reassessment notice issued to an entity that had ceased to exist after conversion into an LLP was invalid. The ruling confirms that tax proceedings cannot continue against non-existent entities.

Unexplained investment addition relying solely upon unverified excel sheet and loose sheet cannot be sustained

November 20, 2025 1008 Views 0 comment Print

ITAT Mumbai held that addition towards unexplained investment u/s. 69A/69B relying solely upon unverified excel sheet, loose sheet and uncorroborated statements, has traversed beyond the permissible confines of evidentiary inference. Accordingly, addition is liable to be deleted.

Reopening of assessment for wrong year is illegal and unsustainable

November 20, 2025 639 Views 0 comment Print

ITAT Indore held that the registered sale-deed would relate back to and have effect from 26.03.2013 falling with previous year 2012-13 relevant to AY 2013-14 and hence the impugned transaction of sale was taxable in AY 2013-14 and not in 2014-15. Accordingly, reopening of assessment for AY 2014-2015 is illegal and unsustainable.

Transfer order u/s. 127 made without serving notice upon assessee is invalid and inoperative

November 19, 2025 1113 Views 0 comment Print

ITAT Indore held that the order under section 127 of the Income Tax Act made out by authorities, without serving notice upon assessee, would be invalid and inoperative. Accordingly, action undertaken by AO u/s. 147/148 will also be illegal.

ITAT Quashes Reassessment After 3 Years for Invalid Sanction

November 19, 2025 1341 Views 0 comment Print

The case examines whether a Section 148 notice issued after the extended limitation period was invalid. Key takeaway: approval beyond three years required the higher authority under Section 151(ii), making the notice vulnerable.

Tribunal Deletes ₹10.84 Cr Addition: Proper Sale Proceeds Ignored, Verified Loans Misread

November 19, 2025 474 Views 0 comment Print

The ITAT Mumbai deleted Rs. 10.84 crore addition made under Section 68, ruling that the assessee had properly documented loans and repayments. Key takeaway: Genuineness of transactions with third-party entities can neutralize claims of unexplained credits.

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