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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 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 333 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 786 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 300 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


Bogus Purchase: ITAT Quashes 271(1)(c) Penalty as Specific Limb not Mentioned

November 12, 2025 981 Views 0 comment Print

 ITAT Mumbai deleted a penalty under Section 271(1)(c) because the notice failed to specify whether it targeted concealment of income or inaccurate particulars. The ruling highlights the need for clarity in issuing tax penalties.

Extrapolation cannot be done to assume income without any cogent material

November 12, 2025 804 Views 0 comment Print

ITAT Mumbai held that no extrapolation can be done on estimation basis in absence of any incriminating material. Accordingly, addition rightly deleted by CIT(A). Thus, order of CIT(A) upheld and appeal of revenue dismissed to that extent.

ITAT Delhi Remands ₹61 Lakh Property Addition – Additional Evidence Admitted Under Rule 29

November 12, 2025 300 Views 0 comment Print

ITAT Delhi remitted a case where CIT(A) upheld additions without examining available evidence. The ruling reinforces that authorities must fully consider documents and explanations before confirming unexplained investments.

Identity Proved, Genuineness Unclear: ITAT Remands ₹50 Lakh Loan Case to AO

November 12, 2025 750 Views 0 comment Print

The ITAT Mumbai remanded a ₹50 lakh addition case after finding that a business loan was omitted from audited accounts and required further verification.

ITAT Upholds 5% Income Estimation on Accommodation Entry Transactions

November 11, 2025 678 Views 0 comment Print

The tribunal dismissed both assessee and Revenue appeals, confirming that income from accommodation entries can be estimated at 5% of credit entries in the bank. The ruling clarifies that when commissions are claimed on transactions without actual goods delivery, a reasonable percentage can be applied to determine taxable income.

Bogus Purchases Allegation Unexamined- ITAT Orders De Novo Adjudication

November 11, 2025 360 Views 0 comment Print

Tribunal held that the CIT(A) erred by annulling assessment without addressing issue of alleged bogus purchases and directed a denovo adjudication on merits in compliance with Section 250(4) and (6).

AO Cannot Ignore Correct DVO Valuation, ₹9.87 Cr Section 69B Addition Deleted

November 11, 2025 714 Views 0 comment Print

 Tribunal clarified that a DVO report, being an estimation, cannot form sole basis for additions under Section 69B. Without proof of actual extra expenditure by assessee, such additions are legally unsustainable.

Vague Penalty Notices Without Specified Limb Are Invalid in Law: ITAT Delhi

November 11, 2025 738 Views 0 comment Print

ITAT Delhi held that penalties were invalid where the Assessing Officer failed to specify the exact charge—concealment, inaccurate particulars, under-reporting, or misreporting. The Tribunal reaffirmed that vague notices under Sections 271(1)(c) or 270A are legally unsustainable.

Reopening Beyond Four Years Without Alleging Assessee’s Failure Is Void

November 11, 2025 771 Views 0 comment Print

The ITAT Delhi held that reassessment under Section 147 was invalid where the AO failed to record any allegation of the assessee’s failure to disclose material facts. The ruling reaffirms that reopening beyond four years requires strict compliance with the proviso to Section 147.

Section 148 Notice Issued to Dead Person is Null & Void: Bombay HC

November 11, 2025 1173 Views 0 comment Print

Bombay High Court quashed reassessment notices and order for AY 201819 after finding they were issued to a deceased individual, explaining that jurisdiction requires serving a living person.

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