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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


Section 263 Revision Quashed Due to Pending Appeal on Same Issue Before CIT(A)

April 1, 2026 480 Views 0 comment Print

The ITAT held that the PCIT cannot invoke revisionary powers when the same issue is already pending before the appellate authority. The case involved share transaction additions treated as penny stock. 

SC Upholds Quashing of Reopening Tax Notice Due to IBC Clean Slate Doctrine

April 1, 2026 528 Views 0 comment Print

The Court held that once a resolution plan is approved, prior tax liabilities stand extinguished. Reassessment under Section 148 was therefore unsustainable.

Reassessment Notice Quashed Due to Extinguishment of Tax Liabilities Under Approved Resolution Plan

April 1, 2026 639 Views 0 comment Print

The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. The notice under Section 148 was set aside. The ruling confirms that extinguished claims cannot be revived through reassessment.

Reassessment Notice Invalid Due to Absence of PCCIT Approval Beyond Three Years

March 31, 2026 930 Views 0 comment Print

ITAT held that reassessment notice issued after three years without PCCIT approval violates Section 151(ii). The approval taken from PCIT was found insufficient. The ruling confirms that proper authority approval is mandatory for valid reassessment.

ITAT Mumbai Quashed Reassessment Due to Wrong Assessment Year in Recorded Reasons

March 31, 2026 378 Views 0 comment Print

The Tribunal rejected reopening based on common reasons for multiple years without year-specific justification. The absence of relevant material for AY 2010–11 led to quashing of reassessment. The ruling stresses precision in reopening proceedings.

SC Set Aside Reassessment Notice Due to Non-Disclosure of Material Facts by Revenue

March 31, 2026 483 Views 0 comment Print

The issue was whether reassessment can proceed without disclosing full allegations to the taxpayer. The Court held that failure to provide an opportunity to respond violates natural justice. The key takeaway is that reassessment notices must clearly communicate all grounds.

No Capital Gains Tax on Sale of Agricultural Land Beyond Municipal Limits: ITAT Ahmedabad

March 31, 2026 945 Views 0 comment Print

The issue was whether sale of agricultural land attracts capital gains tax. The Tribunal held that land situated beyond prescribed municipal limits is not a capital asset. The key takeaway is that location plays a decisive role in taxability.

Section 148 notice issued beyond statutory six-year limitation period is invalid: Bombay HC

March 31, 2026 534 Views 0 comment Print

The Court held that a Section 148 notice issued beyond the statutory six-year limitation period is invalid. It ruled that expired limitation cannot be revived through later amendments, rendering the reassessment void.

Section 50C Not Applicable to Stock-in-Trade? ITAT Remands for Fresh Verification

March 31, 2026 345 Views 0 comment Print

The Tribunal held that Section 50C may not apply if properties are held as stock-in-trade. It remanded the case to verify whether transactions were part of real estate business.

Reassessment Notice for AY 2015-16 Quashed as Time-Barred Due to Post-1st April 2021 Issuance

March 31, 2026 390 Views 0 comment Print

The court held that reassessment notices for A.Y. 2015–16 issued after 1 April 2021 are invalid based on the Revenue’s concession before the Supreme Court. All consequential proceedings were set aside.

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