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Section 148

Latest Articles


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 105 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 189 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


Chhattisgarh HC Set Aside Reassessment Order Due to Non-Compliance with SC Rulings

April 10, 2026 309 Views 0 comment Print

The Court quashed the Section 148A(d) order for not aligning with binding Supreme Court decisions. It directed fresh adjudication following the principles laid down in earlier rulings.

Gujarat HC Quashed Reassessment Notice Issued Beyond 10-Year Limitation Period

April 10, 2026 330 Views 0 comment Print

The Court examined whether reassessment based on search could extend beyond statutory timelines. It held that the notice for AY 2015–16 was issued beyond the permissible ten-year period. The ruling confirms that limitation provisions must be strictly followed.

Reassessment Notice Quashed Due to Incorrect Assumption of Share Transfer: Delhi HC

April 10, 2026 216 Views 0 comment Print

The issue involved reopening based on alleged share transfer through a loan structure. The Court held reassessment invalid as the foundational fact was incorrect.

Reassessment Beyond 10-Year Limit Invalid: Gujarat HC Quashes Notice for AY 2012-13

April 10, 2026 228 Views 0 comment Print

The case involved reassessment triggered by a search conducted in 2022. The Court ruled that reopening beyond the 10-year statutory limit is not permissible.

SC Dismisses Revenue’s SLP Due to Delay & Lack of Year-Specific Material in Reassessment

April 10, 2026 423 Views 0 comment Print

The Supreme Court dismissed the Revenue’s appeal citing unexplained delay and no merit in challenging the High Court ruling. The High Court had quashed reassessment for lack of facts specific to relevant assessment years.

SC Dismisses SLP Due to Delay, Upholds Quashing of Reassessment on Settled Section 80P Issue

April 10, 2026 327 Views 0 comment Print

The case involved reopening of assessment on deduction under section 80P(2)(d). The Supreme Court dismissed the SLP as time-barred, leaving intact the High Court ruling that reassessment was invalid on a settled issue.

No Reassessment on Section 80P Deduction Covered by Binding Precedent: Gujarat HC

April 10, 2026 321 Views 0 comment Print

The court held that reopening of assessment was invalid since the deduction issue was already settled in favour of the assessee. It ruled that reassessment cannot be based on an issue covered by binding precedent.

APMC Gets Full Exemption – ITAT Condones Delay & Quashes Assessments Despite PAN Error

April 9, 2026 252 Views 0 comment Print

The tribunal addressed whether delay in filing appeals due to procedural difficulties justified condonation. It held that genuine hardship caused by PAN mismatch and filing issues constituted sufficient cause, allowing the appeal.

Assessment order void as approval u/s. 153D granted in mechanical manner without application of mind

April 9, 2026 372 Views 0 comment Print

ITAT Delhi held that granting of mandatory approval under section 153D of the Income Tax Act by Additional Commissioner of Income Tax in a mechanical manner and without due application of mind is an empty ritual. Thus, order held void-abinitio for want of valid approval u/s. 153D.

Reassessment u/s. 148 based on mere change of opinion is impermissible in law

April 7, 2026 432 Views 0 comment Print

ITAT Pune held that reopening of assessment under section 148 of the Income Tax Act based on audit objection is merely change of opinion and the same is impermissible in law. Accordingly, notice issued u/s. 148 is not valid and is liable to be quashed.

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