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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 14058 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 2820 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 1050 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

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 249 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 576 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 285 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 279 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 225 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 58935 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


ITAT Delhi Quashes Reassessment Beyond Four Years for Lack of Disclosure Failure

June 6, 2026 318 Views 0 comment Print

ITAT Chennai held that reopening an assessment after four years based on issues already examined during scrutiny amounted to an impermissible change of opinion. The key takeaway is that reassessment cannot be used as a tool to review a concluded assessment without fresh tangible material.

Penny Stock Addition Fails: ITAT Says Suspicion Cannot Replace Evidence

June 6, 2026 519 Views 0 comment Print

The Tribunal deleted the addition after finding that the taxpayer had furnished complete documentary evidence of purchase and sale of shares. The ruling emphasizes that suspicion, however strong, cannot replace legally admissible evidence.

Borrowed Satisfaction: ITAT Quashes Penny Stock Additions in Multiple Family Cases

June 6, 2026 693 Views 0 comment Print

ITAT Delhi held that reassessment based solely on Investigation Wing reports without independent enquiry is invalid. The ruling emphasizes that borrowed satisfaction cannot justify reopening under Section 147.

Statement Alone Cannot Justify ‘On-Money’ Addition: ITAT Mumbai

June 6, 2026 1413 Views 0 comment Print

The Tribunal ruled that statements of builder group officials, without corroborative evidence against the purchaser, cannot form the sole basis for addition. The decision reinforces the principle that third-party statements must be independently verified.

Accepted Disclosure Cannot Be Treated as Misreporting for Penalty Purposes: ITAT Surat

June 6, 2026 357 Views 0 comment Print

The Revenue sought to levy penalty despite accepting the revised income declared by the assessee. ITAT held that accepted disclosures do not automatically amount to misreporting and cannot justify penalty under Section 270A.

Reassessment Quashed as AO Taxed Capital Gains Instead of Recorded Escapement Issue

June 6, 2026 324 Views 0 comment Print

The ITAT held that reassessment cannot be sustained when additions are ultimately made on issues not mentioned in the recorded reasons for reopening. The AO’s jurisdiction failed because no valid addition survived on the original escapement issue.

AO Cannot Reopen on the Same Material Examined in U/s 153C Assessment: ITAT Quashes ₹2.90 Crore Addition

June 6, 2026 264 Views 0 comment Print

ITAT Delhi held that reassessment under Sections 147/148 cannot be based on the same material already examined during a completed Section 153C assessment. The ruling emphasizes that fresh tangible material is necessary for valid reopening.

Reassessment Quashed: Co-owner’s Share Below ₹50 Lakh, Notice Held Time-Barred

June 6, 2026 201 Views 0 comment Print

The Tribunal found that the Assessing Officer ignored the statutory threshold for reopening assessments beyond three years. The ruling emphasizes that reassessment notices issued contrary to limitation provisions are void in law.

APMC Cess Does Not Prove Unaccounted Turnover: ITAT Mumbai

June 6, 2026 150 Views 0 comment Print

ITAT found that the Assessing Officer incorrectly treated consignment transactions as the assessees turnover based solely on cess payments. The ruling emphasizes that commission agents should be taxed on commission income and not on consignors turnover.

Section 68 Addition Deleted as Revenue Failed to Prove Penny Stock Allegation

June 5, 2026 354 Views 0 comment Print

ITAT Mumbai held that additions under Sections 68 and 69C could not be sustained where the Revenue relied only on generalized investigation findings. The Tribunal found no evidence linking the assessee to any accommodation entry arrangement and deleted both additions.

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