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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 14064 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 2847 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 501 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 43CA Inapplicable to AY 2013-14; Reopening Quashed: Bombay HC

Income Tax : Bombay HC quashed Section 148 reopening for AY 2013-14, holding Section 43CA was inapplicable and stamp duty valuation alone could...

July 8, 2026 57 Views 0 comment Print

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 81 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 420 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 1050 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 309 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 58953 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 6021 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 5991 Views 0 comment Print


Change of Opinion without New Material: ITAT Raipur Quashes Reassessment

April 5, 2025 843 Views 0 comment Print

ITAT Raipur quashes Sec 147 reassessment in ITO Vs Bishambhar Dayal Agrawal. Held reopening based on change of opinion, not new material, is invalid. Cites Kelvinator.

Addition of income which has escaped assessment sustained even if not specifically mentioned in re-opening order

April 5, 2025 750 Views 0 comment Print

Guwahati High Court held that AO can make addition of any other income which has escaped assessment but discovered during re-opening process even if the same is not specifically mentioned in re-opening order.

Section 147/148 Proceedings Not Permissible During Pendency of Section 154 Proceedings: SC

April 5, 2025 11919 Views 0 comment Print

Supreme Court sets aside High Court ruling in S.M. Overseas tax case, restores ITAT order on reassessment under Sections 147/148 of Income Tax Act.

Section 127 Order Mandatory for Transfer of Jurisdiction: ITAT Raipur

April 4, 2025 2415 Views 0 comment Print

In Peter Vaz vs CIT, Bombay HC rules ITAT erred in barring Sec 153C challenge & refusing delay condonation. Cites Rule 27, Balakrishnan (SC). Matter remanded.

Reopening Based on Insight Portal Data Without Independent Opinion Unsustainable

April 4, 2025 1671 Views 0 comment Print

Gujarat High Court held that re-opening of assessment solely relying upon information made available on the insight portal, without forming any independent opinion, is unsustainable in law and hence liable to be quashed.

Non-filing of Form 10B cannot be reason to deny benefit u/s. 11: ITAT Delhi

April 4, 2025 1386 Views 0 comment Print

ITAT Delhi held that rejection of claim of exemption under section 11 of the Income Tax Act for mere non-fling of Form 10B is not justifiable since filing of Form 10B is directory in nature and the same cannot be reason to deny benefit.

Reassessment Under Section 147 Invalid When Based on Search Findings

April 3, 2025 2346 Views 0 comment Print

ITAT Kolkata quashes reassessment u/s 147, stating that search-based findings must follow Section 153C. Read the full case details and judgment summary.

Mechanical Approval with Vague and Scanty Reasons is invalid: ITAT Kolkata

April 3, 2025 1491 Views 0 comment Print

ITAT Kolkata quashes assessment reopening in Sudha Surana case, citing lack of AO’s application of mind and invalid PCIT approval.

Passing of order u/s. 148A(d) without granting adjournment for furnishing reply is untenable

April 3, 2025 1518 Views 0 comment Print

Gujarat High Court held that passing of order u/s. 148A(d) of the Income Tax Act without considering reply filed by the petitioner by not granting adjournment time as prescribed u/s. 148A(b). Thus, order quashed and matter remanded back.

Revision u/s. 263 not tenable when AO has taken plausible view: ITAT Delhi

April 3, 2025 1320 Views 0 comment Print

The assessee is a private limited company. Post completion of assessment u/s. 143(3)/153A, reassessment u/s. 148 was initiated. However, AO accepted the contention of the assessee and passed order u/s. 143(3)/ 147.

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