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Section 148

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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


Section 56(2)(vii)(b) Addition Deleted: Why Pre-Amendment Law Applies to Property Booked in 2012

October 15, 2025 720 Views 0 comment Print

The Tribunal held that since over 70% of the consideration was paid in 2012 against an allotment letter, the transfer was deemed complete in the earlier year under the Income Tax Act, despite the 2016 registration date. This precedent ensures that the stamp duty value difference provision cannot be applied retrospectively to transactions substantially completed before the law changed.

ITAT Mumbai Quashes Reassessment for Time-Barred Section 148 Notice

October 14, 2025 1212 Views 0 comment Print

ITAT Mumbai quashes reassessment (AY 13-14, 14-15) as AO missed the Rajeev Bansal-mandated “surviving limitation.” S. 149 prevails over S. 148A procedural timelines.

Technical Win for Revenue, Substance Win for Taxpayer: ITAT Restores Deductions on Merits

October 14, 2025 387 Views 0 comment Print

The ITAT deleted additions in a search assessment, ruling that the AO couldn’t disallow depreciation or sub-contract expenses solely based on an unverified third-party statement without granting the assessee cross-examination. The Tribunal emphasized that denial of natural justice and reliance on suspicion cannot replace documentary evidence, such as bank payments and TDS.

54B Exemption Denied Review: CIT(A) Ordered to Examine Revenue Records and Crop Details Reason

October 14, 2025 546 Views 0 comment Print

The ITAT set aside a CIT(A) order that allowed a Section 54B capital gains exemption, because the CIT(A) copied a co-owners case ruling without independently verifying the factual evidence of agricultural use. The Tribunal reiterated that the burden to prove agricultural use rests on the assessee and remanded the matter for a fresh, reasoned decision based on factual findings.

Unexplained credits addition on adhoc basis at 5% cannot be sustained: Matter restored

October 14, 2025 495 Views 0 comment Print

ITAT Raipur held that addition towards unexplained credits on estimated basis should be the average GP rate from the preceding 3 years. In the present case the same is taken as 5% without any basis. Accordingly, matter restored back to file of AO.

Section 147 ‘Fishing Net’ Doctrine Upheld: ITAT Voids Reopening for Unrelated Additions

October 14, 2025 357 Views 0 comment Print

The ITAT invalidated a reassessment order because the Assessing Officer (AO) failed to make any addition on the sole issue for which the reassessment was initiated (cash deposits). Citing binding precedent, the Tribunal ruled that once the reason to believe ground is not established, the AO loses jurisdiction to make additions on entirely new issues, quashing the entire assessment.

Give Me 7 Days or Give It Up: Karnataka HC Quashes Reassessment for Short Notice

October 14, 2025 966 Views 0 comment Print

$\text{Karnataka \text{ HC}$ quashes AY 2018-19 reassessment and penalty, ruling that Section 148A(b) notice granting only $\text{5 \text{ days}$ to respond violated the mandatory “not less than seven days” rule.

Faceless Reassessments Must Stay Faceless: Karnataka HC quashes AO Issued Notices

October 14, 2025 1005 Views 0 comment Print

High Court held that reassessment notices/orders issued by the AO, rather than NFAC, are void due to jurisdictional defects. The ruling reinforces procedural fairness and statutory compliance.

No Plot, No Profit, Still Taxed :When AO Shoots the Wrong Person: Middleman Dragged into 56(2)(ix) Tax Trap

October 14, 2025 402 Views 0 comment Print

Saroj Devi Haldiya vs. ITO: The ITAT Jaipur overturned an Rs.75 lakh addition under S. 56(2)(ix) of the Income Tax Act. The Tribunal ruled the reassessment was invalid due to borrowed satisfaction by the Assessing Officer, mechanical approval, and a severe violation of natural justice (two-day notice).

Bogus Share Capital: Reassessment Quashed for Lack of Independent Mind Application by AO

October 13, 2025 1539 Views 0 comment Print

ITAT Jaipur ruled that reassessment under Section 148 based solely on Investigation Wing’s report without independent verification is invalid and void ab initio.

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