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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


Section 148 Notice Quashed for Vague Reasons & Lack of Supporting Material: ITAT Pune

Income Tax : ITAT Pune quashed a Section 148 notice based on vague information and directed deletion of a ₹51.35 lakh addition for lack of su...

July 8, 2026 63 Views 0 comment Print

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 363 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 921 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 297 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 58950 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 5988 Views 0 comment Print


Reassessment Notice Invalid If PCIT Approval is Ritualistic & Mechanical: ITAT Delhi

October 3, 2025 720 Views 0 comment Print

ITAT Delhi sets aside reassessment, ruling the PCIT’s ritualistic S. 151 approval for S. 148 notice invalidates the proceedings; “mechanical approval is fatal.”

Reassessment proceedings u/s. 147 cannot be sustained in absence of valid service of notice

October 3, 2025 1008 Views 0 comment Print

Allahabad High Court held that in absence of valid service of notice under section 148 of the Income Tax Act, proceedings under section 147 of the Income Tax Act for reassessment cannot be initiated. Accordingly, appeal of the assessee allowed.

Rs. 3.50 Cr Bogus Loan Addition: ITAT Delhi Quashes Reassessment Over Wrong PAN & Mechanical Approval

October 3, 2025 636 Views 0 comment Print

ITAT Delhi held that reopening under Section 148 on an incorrect PAN and with mechanical sanction by PCIT is invalid, quashing the Rs. 3.50 crore addition under Section 68 and setting aside reassessment proceedings.

Deduction u/s 54F was allowable even if borrowed funds were utilized for investment in new residential asset

October 1, 2025 1227 Views 0 comment Print

Construction was funded through borrowed money, and assessee sought to utilize the account funds to repay the debt. However, Department denied the request to close the account and release funds citing incomplete construction, use of borrowed funds, non-filing of returns for the relevant assessment years, and non-compliance with Section 54F conditions.

Reassessment u/s. 147 without any fresh and new material is invalid

October 1, 2025 960 Views 0 comment Print

ITAT Indore held that reopening of assessment done by Assessing Officer under section 147 of the Income Tax Act, based on tax audit report already available during original assessment, without any fresh and new material is invalid and liable to be quashed.

ITAT Orders Fresh Hearing on Unexplained Cash Deposits of ₹1.49 Cr & Peak Credit Method

October 1, 2025 537 Views 0 comment Print

Bangalore ITAT restored a case involving Rs.1.49 crore in unexplained cash deposits for fresh assessment, directing the AO to re-examine the source and the CIT(A)’s application of the peak credit method.

Section 148 Notice Beyond 7-Day Grace Period Void: ITAT Delhi Quashes Reassessment

September 29, 2025 1167 Views 0 comment Print

The ITAT Delhi quashed the reassessment against Lombard Portfolio Pvt. Ltd., ruling the Section 148 notice was time-barred. Following the Supreme Court’s mandate in the Ashish Agarwal case.

Reassessment notice was invalid if it was issued beyond the calculated “surviving time” or “last date” time limit

September 29, 2025 1050 Views 0 comment Print

Since the last date, or the surviving time, for issuing a valid notice under Section 148 for this specific case was June 17, 2022 and the actual notice was issued on August 24, 2022, it was clearly barred by limitation.

STCG tax paid u/s. 111A cannot be reclassified u/s. 68 r.w.s. 1115BBE without any basis

September 29, 2025 459 Views 0 comment Print

ITAT Nagpur held that short term capital gain tax paid under section 111A @15% cannot be reclassified as taxable under section 68 read with section 115BBE of the Income Tax Act without any basis. Accordingly, appeal of revenue dismissed.

Reopening Beyond 10 Years Void: ITAT Delhi Quashes ₹2.25 Cr Assessment

September 29, 2025 942 Views 0 comment Print

ITAT Delhi rules that reassessment beyond 10 years is void, holding satisfaction note date governs limitation; ₹2.25 Cr addition for AY 2012-13 deleted.

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