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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 2820 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 1050 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 252 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 579 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 279 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 225 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


Death of Assessee & Missing Records: Mumbai ITAT Limits Bogus Purchase Addition to 8% Profit Element

May 25, 2026 198 Views 0 comment Print

The Tribunal ruled that only 8% of disputed purchases could be added where the assessee had disclosed corresponding sales and made payments through banking channels. Entire purchase disallowance was held to distort true business income.

AO Cannot Tax Entire Sale Consideration as Capital Gain Without Allowing Cost of TDR: Bangalore ITAT

May 25, 2026 156 Views 0 comment Print

The Tribunal ruled that capital gains on Transferable Development Rights must be computed after deducting the purchase cost of TDR from the sale consideration. The case was remanded because the assessee failed to submit documents before the AO earlier.

Gujarat HC Quashes Section 148 Reopening Due to Change of Opinion on Section 50C Valuation

May 25, 2026 297 Views 0 comment Print

Gujarat High Court held that reassessment notices issued after scrutiny assessment were invalid because the Assessing Officer had already examined the Section 50C valuation issue during original proceedings. The Court ruled that reopening amounted to a mere change of opinion.

Telangana HC Quashes Time-Barred Reassessment Notice Under Section 148

May 25, 2026 132 Views 0 comment Print

The Court invalidated the reassessment proceedings after finding the Section 148 notice to be barred by limitation. The ruling highlights that reassessment notices must strictly comply with statutory timelines.

Section 69A Not Applicable to Recorded Bank Loans Tagged as Accommodation Entries: ITAT Mumbai

May 25, 2026 396 Views 0 comment Print

Mumbai ITAT held that Section 69A cannot be invoked where loan transactions are fully routed through banking channels and recorded in regular books of account. The Tribunal deleted the addition despite Revenue alleging the transactions were accommodation entries based on third-party search material.

High-Pitched Assessment Should Be Decided on Merits, Not Buried Under Delay Technicalities: ITAT Bangalore

May 25, 2026 174 Views 0 comment Print

The Bangalore ITAT accepted the assessee’s explanation that medical issues and expiry of the digital signature certificate caused the delay in filing appeal. The Tribunal emphasized that procedural lapses should not deprive an assessee of an opportunity to contest major additions on merits.

ITAT Remands Cash Deposit Addition as Assessee Failed to Prove Business Activity

May 24, 2026 612 Views 0 comment Print

The Hyderabad ITAT ruled that the CIT(A) could not delete unexplained cash deposit additions merely on the basis of submissions and audit reports without supporting documents proving business transactions.

Reassessment Quashed Because Property Was Purchased From Different Entity Than Alleged

May 24, 2026 507 Views 0 comment Print

TAT Chandigarh held that reassessment proceedings were invalid because the property was actually purchased from a different company than the one referred to in the recorded reasons. The Tribunal found absence of any live nexus between the assessee and the alleged incriminating material.

ITAT Quashes Section 148 Notice as Reassessment Was Initiated Beyond Six-Year Limitation

May 24, 2026 738 Views 0 comment Print

The ITAT Visakhapatnam held that a reassessment notice issued after expiry of six years for AY 2015-16 was barred by limitation under the first proviso to Section 149(1). The Tribunal ruled that the amended ten-year reopening period could not revive time-barred cases.

Reopening Invalid as Third-Party Seized Papers Did Not Match Assessee’s Land Transaction: Gujarat HC

May 24, 2026 327 Views 0 comment Print

The Gujarat High Court set aside a Section 148 notice after finding no direct or indirect connection between the assessee and the seized third-party documents. The Court held that reassessment based on vague material and assumptions was unsustainable.

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