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Section 148

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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


Share Value Difference on Exchange for NPO Interest Not Taxable as Perquisite

July 20, 2025 288 Views 0 comment Print

High Court holds reassessment invalid; share value difference on exchange for interest in a not-for-profit entity not taxable as perquisite under Section 2(24)(iv).

ITAT Quashes Reassessment Notices Over Improper Sanction Post-Finance Act, 2021

July 20, 2025 705 Views 0 comment Print

Delhi ITAT sets aside reassessment notices against Sampark Management Consultancy LLP, citing invalid sanction post-Finance Act, 2021, and lack of proper authority approval.

Section 148 Notice Issued After 31.03.2022 Held Invalid: ITAT Visakhapatnam

July 19, 2025 1758 Views 0 comment Print

ITAT Visakhapatnam quashes reassessment for AY 2015-16, holding Section 148 notice issued after 31.03.2022 as time-barred and beyond jurisdiction.

Change of opinion cannot be basis for reassessment proceedings u/s. 148: Madras HC

July 19, 2025 702 Views 0 comment Print

Madras High Court held that reassessment proceedings under section 148 of the Income Tax Act initiated on the basis of change of opinion is invalid. Accordingly, appeal of revenue dismissed and substantial questions of law is answered in favour of assessee.

Reassessment notice issued by non-jurisdictional AO is bad-in-law

July 19, 2025 1515 Views 0 comment Print

ITAT Jaipur held that reassessment notice under section 148 of the Income Tax Act issued by the Assessing Officer [AO], having no jurisdiction, is invalid. Accordingly, assessment order and consequent proceeding are also invalid.

Division Bench Allows Income Tax Appeal Despite Delay; Limitation Not a Bar

July 19, 2025 330 Views 0 comment Print

The Calcutta High Court dismissed an appeal by Mukul Mahanta challenging an income tax assessment, directing the petitioner to file a statutory appeal within 30 days.

Notice for reassessment u/s. 148 issued beyond surviving time limit is time-barred: Gujarat HC

July 18, 2025 918 Views 0 comment Print

Gujarat High Court held that reopening of assessment by issuance of notice under section 148 issued beyond the surviving time limit as prescribed under Income Tax Act read with TOLA is barred by limitation. Accordingly, notice is quashed and writ petition allowed.

Reopening Quashed: AO Relied on Investigation Wing Without Applying Mind

July 17, 2025 1017 Views 0 comment Print

Amritsar ITAT sets aside reassessment against Bhai Industries Pvt. Ltd., citing lack of independent AO application of mind and denial of cross-examination in bogus purchases case.

Mere change of opinion: Bombay HC Quashes Tax Section 148 Reopening notice 

July 17, 2025 768 Views 0 comment Print

Bombay High Court set aside reopening of Genesys International’s AY 2015-16 tax assessment, ruling it a mere change of opinion and citing full disclosure.

Reassessment u/s. 148 quashed as initiated inspite of full and true material disclosure: Bombay HC

July 15, 2025 753 Views 0 comment Print

Therefore, the amount distributed by it to the Petitioner would not qualify as exempt dividend income under Section 10(34) of the Act. This to our mind would be merely a “change of opinion”.

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