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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


Assessment order on surrendered PAN constituted justifiable cause- ITAT Condones 607-Day Delay

August 5, 2025 681 Views 0 comment Print

ITAT Nagpur condones a 607-day delay in Astavinayak Gramin Bigar Sheti’s appeal, ruling that an assessment order on a surrendered PAN constituted justifiable cause.

Failure to file return u/s. 139(1) doesn’t constitute under-reporting within section 270A(2)(b): Penalty deleted

August 4, 2025 2199 Views 0 comment Print

ITAT Ahmedabad held that mere filing of return in response to notice u/s. 148 does not ipso facto justify the invocation of section 270A(2)(b), unless there is a demonstrable act of under-reporting in substance. Thus, penalty deleted as failure to furnish return u/s. 139(1) doesn’t constitute under-reporting.

ITAT Chennai Quashes Reassessment which was Based on mere Audit Objection

August 3, 2025 972 Views 0 comment Print

The ITAT Chennai has quashed a reassessment against Ambattur Constructions, ruling that a mere audit objection without fresh material is not a valid basis for reopening a completed assessment.

Addition towards unexplained out of books cash transaction without cogent evidence cannot be sustained

August 2, 2025 990 Views 0 comment Print

ITAT Raipur held that addition made on account of unexplained out of books cash transaction merely on the basis of certain information without cogent evidence or plausible reasoning has not substance to survive in eye of law. Accordingly, addition deleted.

Reassessment notice quashed as faceless procedure not followed

August 2, 2025 2118 Views 1 comment Print

Telangana High Court held that initiation of reassessment proceeding by issuance of notice without following faceless procedure is bad-in-law. Accordingly, notice issued u/s. 148A and section 148 of the Income Tax Act cannot be sustained.

Addition u/s. 43CA quashed as stamp duty and agreement value difference is less than allowable limit

August 1, 2025 504 Views 0 comment Print

ITAT Pune held that addition by invoking provisions of section 43CA of the Income Tax Act cannot be sustained since the difference between the Stamp Duty Value and agreement value is less than the allowable limit of 5%.

Section 148 Reassessment Notices: Jurisdictional Challenges for Taxpayers

August 1, 2025 2478 Views 0 comment Print

Taxpayers can challenge income tax reassessment notices on jurisdictional grounds, including improper notice formats, non-compliance with case selection criteria, and untimely or unauthorized NAFAC actions.

Permission from PCIT instead of PCCIT for reassessment beyond three years is invalid

August 1, 2025 1023 Views 0 comment Print

ITAT Delhi held that permission of initiation of reassessment proceedings u/s. 148 of the Income Tax Act beyond the period of three years is to be obtained only from Pr. Chief Commissioner of Income Tax. Here, permission obtained from Pr. Commissioner of Income Tax is invalid.

Bombay HC Quashes Income Tax Reassessment Notices Issued by JAO

July 30, 2025 1779 Views 0 comment Print

Bombay High Court sets aside reassessment notices for AY 2017-18, ruling Jurisdictional AO lacks authority to issue them under Faceless Assessment Scheme.

ITAT Delhi quashes section 263 revision as reassessment itself held void ab initio

July 29, 2025 1302 Views 0 comment Print

Delhi ITAT sets aside a Section 263 revision after ruling the underlying reassessment order was void from the start. Reassessment initiated during active regular assessment period is invalid.

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