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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


Reassessment notice u/s. 148 beyond specified limit is time barred

October 10, 2025 1785 Views 0 comment Print

ITAT Mumbai held that reassessment notice under section 148 of the Income Tax Act beyond time limit of six year is barred by limitation and hence liable to be quashed. Accordingly, appeal allowed and notice quashed.

Reopening u/s 147 quashed – AO’s “fishing enquiry” to investigate offshore receipts not valid formation of belief- Reassessment void where AO reopens only to verify PE/offshore claims

October 9, 2025 771 Views 0 comment Print

The ITAT Delhi invalidated the reassessment proceedings against Huawei International, a Singapore resident, for AY 2014-15. The Tribunal ruled that the AO’s attempt to investigate offshore software receipts, based merely.

ITAT Delhi remands ₹16.10 Cr unsecured – loan issue for verification; consequential interest disallowance also to be re-examined – CIT(A) erred in bypassing remand report

October 9, 2025 417 Views 0 comment Print

The ITAT Delhi set aside the CIT(A)’s order deleting a Rs.16.10 Cr unsecured loan addition against Nitin Garg, remanding the issue to the AO. The Tribunal found the CIT(A) erred by not requesting a remand report to verify the lender’s creditworthiness and the source of funds, despite the assessee’s non-compliance during assessment.

Tribunal upheld deletion of disallowance u/s 80-IA on amalgamated units and capped sec. 14A disallowance at actual exempt income

October 9, 2025 342 Views 0 comment Print

It was held that regarding section 80-IA issue, Tribunal relied on its own earlier orders in assessees own cases for AYs 2014-15 and 2016-17. It held that since the power plant was transferred as part of a court-approved amalgamation, the assessee was entitled to step into the shoes of the amalgamating company and claim the deduction.

No addition based solely on a third-party document denied by assessee

October 8, 2025 810 Views 0 comment Print

Where the only piece of evidence, AO possessed was the ‘Iqrarnama’, which was not found in the assessee’s possession, was not in their handwriting, and did not bear their genuine signatures, no addition could be made to the assessee’s income, treating it as unexplained money and interest.

Reassessment u/s 147 held invalid when based on search material from third party – Proceedings ought to be u/s 153C

October 7, 2025 1413 Views 0 comment Print

The Karnataka High Court ruled that when reassessment is based solely on material seized from a third-party search, the Income Tax Department must follow the specific procedure under Section 153C of the IT Act, not the general Section 147.

Reassessment u/s 148A by Jurisdictional AO beyond scope of Sec 151A quashed by Karnataka HC

October 7, 2025 1050 Views 0 comment Print

Karnataka HC quashes reassessment and penalty orders after finding the Jurisdictional AO initiated Sec 148A proceedings outside the scope of the Faceless Regime (Sec 151A).

Delhi HC Upholds Reopening Based on ‘Yes, I Am Convinced’ Approval

October 7, 2025 966 Views 0 comment Print

Delhi High Court upheld reassessment for Agroha Fincap, ruling that the sanction “Yes, I am convinced it is a fit case” meets Section 151 requirements, rejecting the ITAT’s finding of mechanical approval.

ITSC Applications Filed Before 31 March 2021 to Be Treated as Pending

October 7, 2025 381 Views 0 comment Print

Delhi High Court rules ITSC applications filed until March 31, 2021, are valid and must be treated as pending. Retrospective cut-off of February 1, 2021, is arbitrary, violating Article 14.

Faceless AO Ignored Evidence of Family Funding – Tribunal Restores Justice for Homemaker

October 7, 2025 378 Views 0 comment Print

Judicial ruling confirms that investment source for property purchased by a homemaker was genuine. The ITAT found that the entire consideration had a clear trail from the son’s account, reversing the mechanical addition made by lower authorities.

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