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Section 148

Latest Articles


A comprehensive analysis of function of electronic information in tax assessments

Income Tax : Explore how electronic data transforms tax assessments, highlighting accuracy issues, verification needs, and taxpayer rights as s...

August 7, 2024 870 Views 0 comment Print

Note on Income Tax Notices Issued: Section148 read with Section 135A

Income Tax : Learn about the revised procedure for reopening cases under Section 148 RWS 135A and the implications of Finance Act 2021, includi...

July 31, 2024 2634 Views 0 comment Print

Budget 2024: Rationalization of Income Tax Re-assessment Provisions

Income Tax : Discover the key amendments in the Finance (No.2) Bill, 2024, affecting income tax reassessment procedures under the Income-tax Ac...

July 25, 2024 1161 Views 0 comment Print

Bombay HC Invalidates Reassessment Notice for AY 2015-16: Lack of DIN & Jurisdictional Issue

Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...

July 6, 2024 999 Views 0 comment Print

Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1620 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 546 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 1077 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 6483 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 6954 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 12912 Views 0 comment Print


Latest Judiciary


CIT needs to independently apply his mind prior to invoking revisionary provisions u/s. 263: ITAT Kolkata

Income Tax : ITAT Kolkata held that CIT has not applied his mind analytically while assuming jurisdiction for taking cognizance under section 2...

August 16, 2024 60 Views 0 comment Print

Addition u/s. 68 restored on failure to discharge onus via evidence or material: ITAT Pune

Income Tax : ITAT Pune restored the assessment order as assessee neither filed any evidence nor provided material in an attempt to discharge th...

August 16, 2024 96 Views 0 comment Print

Reassessment action u/s. 148 post approval of resolution plan unsustainable: Delhi HC

Income Tax : Delhi High Court held that reassessment action under section 148 of the Income Tax Act post approval of the resolution plan unsust...

August 15, 2024 522 Views 0 comment Print

Written request to existing AO needs to be made for migrating PAN to new AO due to address change: Patna HC

Income Tax : Patna High Court held that for migrating PAN to new AO, due to change in address, a written request to existing AO must be made. S...

August 13, 2024 165 Views 0 comment Print

Dismissal of appeal for non-payment of self-assessment tax unjustified as no tax was payable due to losses: ITAT Hyderabad

Income Tax : ITAT Hyderabad held that dismissal of appeal by CIT(A) on the ground of non-deposition of self-assessment tax by the assessee need...

August 13, 2024 222 Views 0 comment Print


Latest Notifications


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 15738 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 3288 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 5376 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 2949 Views 0 comment Print

Carry out due verification before initiating Section 148/147 proceedings: CBDT

Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...

August 22, 2022 13530 Views 0 comment Print


Reopening of assessment under Section 147/148 not permissible when final settlement order under Section 245D(4) has been passed

March 20, 2024 882 Views 0 comment Print

Delve into the crucial judgment of Orchid Infrastructure Developers Pvt Ltd Vs PCIT, where the Delhi High Court ruled against reopening assessments under Section 147/148 after a final settlement order under Section 245D(4).

Goods smuggled from Foreign Origin without customs clearance in absence of reasons to believe was invalid

March 20, 2024 402 Views 0 comment Print

In the absence of “reason to believe” recorded by the authorities, revenue authorities had hopelessly failed to bring out to recordthat  the goods (here Arecanuts) imported from outside the country was without valid customs clearance.

Failure to substantiate identity & fund source: Kolkata ITAT Remits Matter for Re-adjudication

March 19, 2024 219 Views 0 comment Print

Kolkata ITAT remits case of Dahisar Traders Pvt Ltd vs ITO due to failure in substantiating identity & fund source, demanding re-adjudication. Full order details.

Addition which is not based on reasons for reopening is un-sustainable sans notice u/s 148

March 19, 2024 1182 Views 0 comment Print

Read the detailed analysis of Manu Stock Broking Pvt Ltd Vs ACIT case by Mumbai ITAT. Learn how additional issues impacted proceedings under section 147/148 of the Income Tax Act.

Section 50(C)(2): If taxpayer objects to valuation, AO must refer valuation to valuation officer

March 19, 2024 675 Views 0 comment Print

Mumbai ITAT orders AO to follow Sec 50C if stamp values exceed property FMV, in Rakhmabai Mhatre Mukkam Bhalgaon vs ITO case. Full text available.

Reopening of assessment u/s. 148 based on reason to suspect is unsustainable-in-law: ITAT Delhi

March 19, 2024 1290 Views 0 comment Print

ITAT Delhi held that reopening of assessment under section 148 of the Income Tax Act based on reason to suspect unsustainable as AO failed to demonstrate live link between tangible material and formation of reason to believe that income had escaped assessment.

I&B Code Proceedings and Moratorium Render Appeals Invalid

March 19, 2024 267 Views 0 comment Print

Learn about the ITAT Mumbai ruling that prohibits filing appeals during a moratorium under section 14 IBC, as seen in the case of Kaushal Silk Mills Pvt. Ltd. vs ITO.

Interconnect Usage Charges Not Taxable as Royalty: ITAT Bangalore

March 19, 2024 249 Views 0 comment Print

HCG Global Communications Ltd. vs. DCIT (ITAT Bangalore) case ruling: Telecom interconnect usage payments received by a foreign company from an Indian operator deemed non-taxable as ‘royalty’ under the Income Tax Act.

Mere Retracted Statement without nexus Insufficient for Section 69A Addition

March 19, 2024 423 Views 0 comment Print

Mumbai ITAT rules that a retracted statement without nexus to the taxpayer cannot justify addition under Sec 69A, offering relief to the appellant in Mayur Kanjibhai Shah Vs ITO.

Reopening u/s. 148 merely based on investigation report is unjustifiable: ITAT Delhi

March 19, 2024 1152 Views 0 comment Print

ITAT Delhi held that reopening assessment under section 148 of the Income Tax Act merely based on the investigation report without concluding the nature of alleged accommodation entry is unjustifiable and liable to be quashed.

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