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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 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 14058 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 2823 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 1053 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

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 258 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 615 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 285 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 285 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 58935 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


ITAT Remands Reassessment Case Due to Failure to Examine Additional Evidence

June 11, 2026 198 Views 0 comment Print

ITAT Delhi set aside the assessment after finding that the assessees additional evidence had not been properly scrutinized by the tax authorities. The Tribunal emphasized adherence to principles of natural justice before sustaining additions.

Period of limitation prescribed under Income-tax Act, 1961

June 11, 2026 6018 Views 1 comment Print

A detailed overview of limitation periods prescribed under the Income-tax Act reveals how missing statutory deadlines can lead to penalties, loss of deductions, exemptions, and legal remedies. The key takeaway is that timely compliance with filing, assessment, appeal, audit, and tax payment obligations is crucial to avoid adverse tax consequences.

Share Premium Can’t Be Taxed U/s 68 Merely Because AO Finds It Excessive: Mumbai ITAT

June 11, 2026 330 Views 0 comment Print

The Tribunal ruled that the Assessing Officer cannot tax share premium under Section 68 solely on the basis that the premium lacks commercial justification. Valuation concerns fall outside the scope of Section 68 for years prior to the introduction of Section 56(2)(viib).

Reassessment Beyond Four Years Invalid Without Finding of Failure to Disclose Material Facts: ITAT Delhi

June 11, 2026 588 Views 0 comment Print

The ITAT held that reassessment initiated beyond four years cannot survive unless the Assessing Officer records that the assessee failed to fully and truly disclose material facts. Since the recorded reasons contained no such allegation, the notice under Section 148 was declared invalid. The consequential reassessment order was quashed.

AO cannot introduce a new addition while giving effect to appellate order: ITAT Chennai

June 11, 2026 342 Views 0 comment Print

The ITAT Chennai held that an Assessing Officer cannot introduce a new addition while giving effect to an appellate order. Since the Tribunal had issued no direction to tax ₹5 crore as income from other sources, the addition was deleted.

ITAT Deletes Investment Addition as Bank Records Proved Source of Funds Despite Non-Production of Mother

June 11, 2026 186 Views 0 comment Print

ITAT found that the assessee had sufficient cash resources to meet the impugned credit card payments. Since the authorities did not establish utilisation of cash elsewhere, the addition was deleted.

Delhi HC questions Denial of Prepaid Tax Credit Solely Because Return Was Filed After Section 148 Notice

June 11, 2026 246 Views 0 comment Print

The High Court questioned the Revenue’s refusal to grant credit for advance tax and TDS despite substantial amounts already lying with the Government. The matter was directed towards reconsideration through a fresh assessment.

Income Tax Reopening Quashed as PAN Was Not Properly Transferred to Jurisdictional Officer

June 11, 2026 621 Views 0 comment Print

Bombay High Court quashed income tax reassessment proceedings after holding that the PAN was not transferred to the competent jurisdictional officer and the Section 148 notice was issued by an officer lacking authority.

Pre-1 Oct 2009 Share Gifts Not Taxable Under Section 56(2)(vii)(c): ITAT Mumbai

June 11, 2026 195 Views 0 comment Print

The ITAT Mumbai held that gifts of shares completed before the introduction of Section 56(2)(vii)(c) could not be taxed under that provision. The ruling clarifies that subsequent procedural formalities cannot alter the original date of transfer.

ITAT Quashes Reassessment as Reasons Recorded for Section 148 Notice Were Unsigned

June 11, 2026 588 Views 0 comment Print

The Delhi ITAT held that unsigned reasons recorded for reopening assessment constituted a jurisdictional defect that invalidated the reassessment proceedings. The defect was not curable under Section 292B of the Act.

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