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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 336 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 345 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 837 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 306 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


Reassessment Notices beyond Limitation – ITAT Delhi Quashes Proceedings

October 30, 2025 435 Views 0 comment Print

ITAT Delhi quashed reassessment proceedings for AY 2013-14 and 2015-16, ruling that notices issued after the extended final deadline of June 24, 2022, were time-barred under Section 149, following the Rajeev Bansal ruling.

Payment towards bandwidth services cannot be characterized as royalty under India-UAE DTAA

October 30, 2025 585 Views 0 comment Print

ITAT Mumbai held that payment towards bandwidth service without transfer of right to use equipment or process could not be characterized as ‘royalty’ under section 9(1)(vi) or Article 12 of India-UAE DTAA. Thus, appeal decided in favour of assessee.

Lower of book loss or unabsorbed depreciation to be set off against book profits as per section 115JB

October 30, 2025 1149 Views 0 comment Print

ITAT Delhi held that as per the MAT provisions of section 115JB of the Income Tax Act the lower of book losses or unabsorbed depreciation can be set off against book profits. Accordingly, order of CIT(A) upheld and appeal of assessee dismissed.

ITAT Remands Case to CIT(A) After Assessee Agrees to Cooperate

October 30, 2025 735 Views 0 comment Print

Chennai ITAT remanded an ex parte assessment back to the CIT(A) after the assessee filed an affidavit promising full cooperation and no adjournments. The appeal was allowed for statistical purposes.

Reassessment Quashed: Approval for Notice Beyond 3 Years Must Be PCCIT, Not PCIT

October 29, 2025 1377 Views 0 comment Print

ITAT Delhi nullified a reassessment, ruling that mandatory sanction under Section 151 was invalid because it was granted by Principal Commissioner (PCIT). Tribunal held that reopening assessments after three years requires approval from higher authority: Principal Chief Commissioner (PCCIT).

Search Assessment Barred: Limitation Period Starts When AO Gets Seized Papers

October 29, 2025 756 Views 0 comment Print

ITAT Delhi dismissed the Revenue’s appeal, ruling that the assessment under Section 153C was time-barred because the block period must be calculated from the date the Assessing Officer (AO) of the non-searched person received the seized material. The ruling confirms that the date of the original search is irrelevant for non-searched persons.

 ITAT Delhi Quashes 43 Search Assessments for Mechanical 153D Approvals

October 29, 2025 696 Views 0 comment Print

ITAT Delhi set aside 43 search assessments involving a business group and its associates, ruling that the mass approvals granted under Section 153D were invalid.1 The Tribunal held that approving 23 draft orders within 24 hours without proper review constitutes a mechanical, non-judicial exercise of power.

ITAT Mumbai Reduces 100% Bogus Purchase Addition to Nominal GP Difference

October 29, 2025 1245 Views 0 comment Print

Tribunal held that when sales are accepted and supported by evidence, entire purchases cannot be disallowed. Only the profit element can be added, restricting disallowance to ₹8,075 as per Bombay High Court’s ruling in Mohammad Haji Adam & Co.

Revised Return After Detection Not Voluntary – ITAT Upholds 200% Misreporting Penalty

October 28, 2025 4968 Views 0 comment Print

ITAT Pune held that filing a revised return after the Department detects wrong deductions is not voluntary. Since the assessee acted only after detection, penalty u/s 270A(9) for misreporting was rightly imposed at 200% of tax.

Penny Stock Gains Upheld as Genuine – ITAT Quashes Reopening for Lack of Fresh Material

October 28, 2025 828 Views 0 comment Print

ITAT Pune held that reopening based on old investigation data was invalid where transactions were already verified under Section 153A. The Tribunal found the penny stock gains genuine as supported by Demat, bank, and STT records.

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