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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 309 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 726 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 297 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 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 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


Approval from PCIT Instead of PCCIT Invalidates Section 148 Notice: ITAT Pune

November 2, 2025 1080 Views 0 comment Print

ITAT Pune annulled reassessment proceedings, holding that approval by PCIT instead of PCCIT for notices issued after three years was contrary to Section 151.

Bombay High Court Quashes Reassessment Notice for Invalid Sanction

November 2, 2025 711 Views 0 comment Print

The Court found reassessment action void as sanction was not granted by the competent authority and directed the Department to share the approval copy with the assessee

Mechanical Reopening Without Considering Reply Invalid: Delhi HC

November 2, 2025 534 Views 0 comment Print

Delhi HC set aside Section 148A order against Michael and Susan Dell Foundation, ruling the AO failed to consider the detailed submission, violating natural justice principles.

Transfer of Case Within Same City Needs No Fresh Notice: ITAT Upholds Reassessment

November 2, 2025 297 Views 0 comment Print

ITAT clarified that transfer of case between officers in the same city does not require a new notice or hearing, reinforcing that procedural continuity under Section 127(4) ensures jurisdictional validity.

Donation & Salary Kickback: ITAT Ahmedabad Partly Upholds Additions

November 2, 2025 627 Views 0 comment Print

ITAT Ahmedabad partly allowed the Revenue’s appeal, fully upholding the addition for salary kickbacks based on overwhelming seized evidence showing a routine, systematic practice. The Tribunal confirmed that this consistent pattern justified extrapolation for the full year.

Typo Error in Recorded Reasons Doesn’t Invalidate Reassessment on Penny Stock LTCG

November 2, 2025 450 Views 0 comment Print

Rejecting assessee’s plea of invalid reopening, Tribunal ruled that minor clerical mistakes in reasons recorded under Section 147 do not vitiate proceedings if substantive material exists. Information disseminated through Insight Portal was sufficient to establish AO’s belief.

ITAT Chennai Remands Reassessment on Capital Gains & Section 44AD Additions

November 2, 2025 432 Views 0 comment Print

The ITAT restored the ₹1.11 Cr capital gains addition for the sale of alleged agricultural land back to the AO for fresh verification. The matter was sent back due to the assessee’s non-compliance and non-submission of evidence in prior proceedings.

Reopening Validated: Dual PANs & Huge Cash Deposits Are Tangible Material

November 2, 2025 660 Views 0 comment Print

ITAT Delhi upheld reassessment on an individual for AY 2017-18, finding that existence of dual PANs and huge undisclosed demonetization cash deposits constituted tangible material. Tribunal confirmed that sufficiency of material is irrelevant at reopening stage, only prima facie belief matters when notice is issued within four years.

Deemed dividend not taxable when borrower doesn’t hold shares in lender company

November 1, 2025 678 Views 0 comment Print

ITAT Indore held that Deemed Dividend under section 2(22)(e) of the Income Tax Act is not taxable in hands of borrower-company who doesn’t hold shares in lender-company. Accordingly, appeal of the assessee allowed and addition set aside.

Bombay High Court Quashes Reassessment for Invalid Service and Approval

November 1, 2025 3288 Views 0 comment Print

The Court held that reassessment proceedings under Sections 148A and 148 were void as notices were not validly served and proper approval from PCCIT was not obtained.

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