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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 2823 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 1053 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 258 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 615 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 285 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 228 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


Section 148 Notice Quashed as Escaped Income Was Below ₹50 Lakh & Issued After 3 Years

June 5, 2026 333 Views 0 comment Print

The ITAT Mumbai held that a reassessment notice issued beyond three years was invalid where the alleged escaped income was less than ₹50 lakh. The consequential assessment order was quashed.

ITAT Quashes Reassessment as Assessment Was Framed by Officer Who Did Not Issue Section 148 Notice

June 5, 2026 228 Views 0 comment Print

The Amritsar ITAT held that reassessment proceedings were invalid where the officer completing the assessment had not issued the notice under Section 148. The reassessment order was quashed on jurisdictional grounds.

ITAT Quashes Reassessment as Reopening Was Based on Mere Change of Opinion

June 5, 2026 192 Views 0 comment Print

The Tribunal ruled that reassessment based on a different interpretation of the same material examined during the original assessment amounted to a change of opinion and could not justify reopening.

Reopening of Assessment Invalid as DVO Valuation Was Lower Than Assessee’s Declared Value

June 5, 2026 174 Views 0 comment Print

The Court held that the Assessing Officer could not refer the matter to the Valuation Officer under Section 55A where the assessees registered valuer had reported a higher value. The reassessment based on such reference was therefore held impermissible.

Delhi HC Quashes Reassessment Notice as It Was Issued Beyond Extended Limitation Period

June 5, 2026 1644 Views 0 comment Print

The Court held that while the assessees reply period had to be excluded under Section 149, the Assessing Officer still failed to issue the Section 148 notice within the extended statutory timeline. The reassessment notice was therefore quashed as time-barred.

Reassessment Notice Quashed as Section 148A(b) Procedure Was Not Followed Against Legal Heirs

June 5, 2026 240 Views 0 comment Print

The Rajasthan High Court held that reassessment proceedings against legal representatives of a deceased assessee must comply with Section 148A(b). Notices and orders issued without following the mandatory procedure were quashed.

ITAT Mumbai Restricts Bogus Purchase Addition to 7.87% of profit element

June 4, 2026 504 Views 0 comment Print

The ITAT Mumbai held that purchases cannot be treated as entirely bogus merely based on Sales Tax Department information when the assessee produced invoices, bank statements, stock records, and delivery challans. The Tribunal directed that only the profit element embedded in the alleged non-genuine purchases, if any, should be taxed.

Copy-Paste Reasons Sink Reassessment: Delhi ITAT Quashes Reopening for Non-Application of Mind

June 4, 2026 381 Views 0 comment Print

The Tribunal ruled that reassessment proceedings cannot survive when reasons recorded for reopening demonstrate non-application of mind. Following the Delhi High Court’s findings in the preceding year, the reassessment was declared invalid.

Bangalore ITAT: No 40A(3) Disallowance on Mere Assumptions- Profit Estimation Without Rejecting Books Quashed

June 4, 2026 159 Views 0 comment Print

The Bangalore ITAT held that a Section 40A(3) disallowance cannot be made on the assumption that cash payments might have exceeded statutory limits. The Tribunal deleted the addition after finding that records showed payments were made through banking channels.

Entire Sale Consideration Cannot Be Taxed as Capital Gain: Mumbai ITAT Orders Fresh Computation

June 3, 2026 744 Views 0 comment Print

Mumbai ITAT ruled that where a capital asset was acquired before 01.04.2001, the claim for adopting fair market value as on that date must be examined on merits. The key takeaway is that statutory valuation rights cannot be rejected on technical grounds alone.

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