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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 186 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


Reversal of Previously Disallowed Securitisation Provisions Cannot Be Taxed Again: ITAT Mumbai

May 21, 2026 96 Views 0 comment Print

The Mumbai ITAT held that reversal of securitisation provisions already disallowed in earlier years cannot be taxed again upon write-back. The Tribunal ruled that such taxation would amount to double taxation.

ITAT Mumbai Quashes Reassessment as Section 148 Notice Was Issued Beyond Surviving Limitation Period

May 20, 2026 234 Views 0 comment Print

ITAT Mumbai held that the reassessment notice issued on 24.07.2022 was time-barred under the Supreme Court ruling in Rajeev Bansal. The Tribunal ruled that reassessment proceedings and the consequential assessment order were invalid.

ITAT Delhi Quashes Reassessment as Reopening Was Based Only on Audit Objection

May 20, 2026 162 Views 0 comment Print

The Delhi ITAT held that reassessment proceedings initiated solely on the basis of a revenue audit objection without fresh tangible material were invalid. The Tribunal ruled that such reopening amounted to a mere change of opinion.

Reassessment Quashed as AO Used Section 147 Instead of Mandatory Section 153C

May 20, 2026 294 Views 0 comment Print

ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 153C and not Sections 147/148. The Tribunal quashed the reassessment for lack of jurisdiction and absence of a mandatory satisfaction note.

Penalty for Unsecured Loans Not Automatic Merely for Section 68 Addition: ITAT Bangalore

May 20, 2026 372 Views 0 comment Print

The Tribunal ruled that the use of the word may in Section 271AAC gives discretionary power to the Assessing Officer and does not mandate automatic penalty levy. It emphasized that such discretion must be exercised judiciously.

ITAT Deletes Addition Because Stamp Duty Value Ignored Illegal Construction

May 20, 2026 321 Views 0 comment Print

The ITAT held that stamp duty valuation could not be blindly adopted where the property was affected by BBMP demolition proceedings for unauthorized construction. The Tribunal accepted the actual purchase price as fair market value and deleted the addition.

Bangalore ITAT Slashes Estimated Profit from 15% to 7% – Best Judgment Assessment Cannot Be a “Blind Guess”

May 20, 2026 117 Views 0 comment Print

The Tribunal ruled that a flat 15% profit estimation was excessive where all contract receipts were received through banking channels with TDS deductions. It directed recomputation of income at 7% of turnover.

Telangana HC Quashes Reassessment by Jurisdictional AOs After Faceless Scheme Implementation

May 20, 2026 144 Views 0 comment Print

The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation of the Faceless Assessment Scheme were without jurisdiction. It quashed notices issued under Sections 148A and 148 along with consequential orders.

Section 56(2)(x) Not Applicable Before 01.04.2017: ITAT Delhi

May 19, 2026 300 Views 0 comment Print

ITAT Delhi held that Section 56(2)(x) could not be applied to property transactions relating to Assessment Year 2017-18 because the provision became effective only from AY 2018-19. The Tribunal deleted the addition made on the difference between stamp duty value and purchase consideration.

Mumbai ITAT Quashes AY 2015-16 Reassessment as Time-Barred – Revenue’s Own Concession in Rajeev Bansal Proves Fatal

May 19, 2026 306 Views 0 comment Print

Mumbai ITAT held that reassessment notice issued under Section 148 for AY 2015-16 on 31.07.2022 was barred by limitation under Section 149. The Tribunal quashed the entire reassessment proceedings and assessment order.

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