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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


Deduction u/s 54F was allowable even if borrowed funds were utilized for investment in new residential asset

October 1, 2025 1026 Views 0 comment Print

Construction was funded through borrowed money, and assessee sought to utilize the account funds to repay the debt. However, Department denied the request to close the account and release funds citing incomplete construction, use of borrowed funds, non-filing of returns for the relevant assessment years, and non-compliance with Section 54F conditions.

Reassessment u/s. 147 without any fresh and new material is invalid

October 1, 2025 888 Views 0 comment Print

ITAT Indore held that reopening of assessment done by Assessing Officer under section 147 of the Income Tax Act, based on tax audit report already available during original assessment, without any fresh and new material is invalid and liable to be quashed.

ITAT Orders Fresh Hearing on Unexplained Cash Deposits of ₹1.49 Cr & Peak Credit Method

October 1, 2025 501 Views 0 comment Print

Bangalore ITAT restored a case involving Rs.1.49 crore in unexplained cash deposits for fresh assessment, directing the AO to re-examine the source and the CIT(A)’s application of the peak credit method.

Section 148 Notice Beyond 7-Day Grace Period Void: ITAT Delhi Quashes Reassessment

September 29, 2025 1125 Views 0 comment Print

The ITAT Delhi quashed the reassessment against Lombard Portfolio Pvt. Ltd., ruling the Section 148 notice was time-barred. Following the Supreme Court’s mandate in the Ashish Agarwal case.

Reassessment notice was invalid if it was issued beyond the calculated “surviving time” or “last date” time limit

September 29, 2025 993 Views 0 comment Print

Since the last date, or the surviving time, for issuing a valid notice under Section 148 for this specific case was June 17, 2022 and the actual notice was issued on August 24, 2022, it was clearly barred by limitation.

STCG tax paid u/s. 111A cannot be reclassified u/s. 68 r.w.s. 1115BBE without any basis

September 29, 2025 438 Views 0 comment Print

ITAT Nagpur held that short term capital gain tax paid under section 111A @15% cannot be reclassified as taxable under section 68 read with section 115BBE of the Income Tax Act without any basis. Accordingly, appeal of revenue dismissed.

Reopening Beyond 10 Years Void: ITAT Delhi Quashes ₹2.25 Cr Assessment

September 29, 2025 900 Views 0 comment Print

ITAT Delhi rules that reassessment beyond 10 years is void, holding satisfaction note date governs limitation; ₹2.25 Cr addition for AY 2012-13 deleted.

Saif Ali Khan Wins Tax Appeal as ITAT Mumbai Strikes Down Defective Reassessment

September 28, 2025 582 Views 0 comment Print

The ITAT Mumbai quashed the reassessment notice against Saif Ali Khan (AY 2016-17), holding the AO improperly obtained approval from the Pr. CIT instead of the Pr. CCIT for reopening beyond the three-year limit.

ITAT Delhi Allows Section 54F Exemption to Private Trust on Capital Gains

September 28, 2025 5919 Views 0 comment Print

Delhi ITAT confirms that a private trust with identifiable beneficiaries is eligible for the capital gains exemption under Section 54F, similar to an individual.

ITAT Restricts Tax on Bank Deposits to Peak Credit – Full Cash Not Taxable

September 28, 2025 978 Views 0 comment Print

Bangalore ITAT restricted the s.69A unexplained cash addition for non-filer Umesh Babu to the peak credit of Rs.12.25 lakhs, rejecting the Rs.ケ57.10 lakhs addition.

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