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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 105 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 189 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


Reopening Cannot Be Quashed Using New Law Retrospectively – Matter Remanded to CIT(A)

April 24, 2026 288 Views 0 comment Print

The reassessment notice issued within four years was wrongly quashed by applying amended law. The Tribunal restored the matter, emphasizing correct application of applicable provisions.

ITAT Bangalore: Legitimate Deductions Cannot Be Denied for Non-Filing-Matter Remanded to Allow Form 16 Claims

April 24, 2026 249 Views 0 comment Print

ITAT ruled that failure to file a return does not justify taxing income without allowing legitimate deductions. The case was sent back to the AO to consider exemptions and deductions available in records.

Search on Others Can’t Extend Reassessment Limit Without Assessee-Specific Seized Material

April 24, 2026 429 Views 0 comment Print

The Court held that the notice issued after six years from the relevant assessment year was barred by limitation. The reassessment proceedings were set aside.

Foreign Tax Credit Allowed if Form 67 Filed Before Assessment Completion

April 24, 2026 192 Views 0 comment Print

The case examined whether late submission of Form 67 can deny FTC. The tribunal held that filing before assessment completion is sufficient and directed allowance of full credit.

Income Tax Reassessment Quashed Due to Approval from wrong Authority: ITAT Pune

April 23, 2026 486 Views 0 comment Print

The Tribunal held that reassessment proceedings were invalid as approval was taken from the wrong authority beyond three years. It ruled that such non-compliance with Section 151(ii) vitiates jurisdiction and renders the notice void.

Telangana HC Quashed Reassessment Due to Invalid Section 151 Approval

April 23, 2026 285 Views 0 comment Print

The case examined whether reassessment proceedings were valid when approval was obtained from an incorrect authority. The Court held the sanction invalid as it did not comply with statutory requirements, rendering the reassessment void. The ruling highlights strict adherence to approval hierarchy in reopening cases.

Offshore Supply Income Not Taxable in India Due to Absence of Business Connection: Delhi HC

April 21, 2026 399 Views 0 comment Print

The judgment confirms that income from offshore equipment supply is not taxable where transactions occur outside India. The liaison office was also held not to create a taxable presence. The case highlights limits of tax jurisdiction over cross-border supplies.

Income Tax Appeal Reinstated as Delay due to Bona Fide Belief & COVID-19 Disruption

April 21, 2026 324 Views 0 comment Print

The Tribunal held that lack of awareness of the assessment order and limited knowledge of tax law constituted sufficient cause for delay. The matter was restored for reconsideration on merits.

Reopening Valid Where Income Escapement Based on Search-Derived Information

April 21, 2026 420 Views 0 comment Print

The Tribunal confirmed addition of unexplained investments where the assessee could not substantiate the source of deposits. The ruling reinforces the burden of proof on the taxpayer.

Section 68 Addition Deleted Due to Lack of Evidence of Bogus Transactions

April 21, 2026 420 Views 0 comment Print

The Tribunal held that mere suspicion of bogus transactions without supporting evidence cannot justify addition under section 68. Proper documentation of sales and purchases led to deletion of the addition.

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