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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 60 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 1059 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 Does Not Justify Assumption of Escaped Taxable Income

February 22, 2024 888 Views 0 comment Print

Uncover the Bombay High Court’s stance on reassessment based on change of opinion in the Mira Bhavin Mehta Vs ITO case. Key insights and legal implications.

HC Quashes reassessment notice & order for absence of application of mind & errors in approval

February 21, 2024 4344 Views 0 comment Print

Bombay High Court quashes reassessment notice against Kartik Gandhi for AY 2019-20, highlighting issues with Section 148 and 151 approvals.

Source for making or earning income of payer of FTS outside India is not taxable in India

February 20, 2024 2682 Views 0 comment Print

ITAT Delhi held that as conditions prescribed in exception to section 9(1)(vii)(b) stand fulfilled, it cannot be taxed as FTS. Further, the source for making or earning any income of the payer of fee for technical services, in the present case, is outside India, and therefore not taxable in India.

Old provisions of section 148 including TOLA cannot be applied to new regime: Calcutta HC

February 20, 2024 4455 Views 0 comment Print

Calcutta High Court held that the provisions of old regime of Section 148 of the Income Tax Act (including TOLA) cannot be applied to new regime applicable from 01.04.2021. Accordingly, impugned notices quashed being barred by limitation.

Section 148 lacks allegations of non-disclosure; jurisdiction assumption U/s. 147 is invalid

February 20, 2024 771 Views 0 comment Print

Delhi High Court finds Section 148 notice flawed due to lack of non-disclosure allegations; declares Section 147 jurisdiction assumption invalid.

3-Year Limit for Tax Reassessment Notice if concealed income below 50 lakh: Jharkhand HC

February 19, 2024 3915 Views 0 comment Print

Explore the Jharkhand High Court judgment limiting tax reassessment period for concealed income below 50 lakh. Detailed analysis of Sevensea Vincom Pvt Ltd vs PCIT case.

Sale of Software License Not Royalty under India-Singapore DTAA: ITAT Delhi

February 15, 2024 1263 Views 0 comment Print

ITAT Delhi rules receipts from the sale of software licenses to Pepsico India and ITC Limited not royalty under India-Singapore DTAA. Read the full analysis.

No Tax on Salary for Non-Resident Assessee Rendering Services Outside India: ITAT

February 15, 2024 1791 Views 0 comment Print

Explore the ITAT Delhi ruling on Devi Dayal Vs DCIT regarding taxation of salary earned by a non-resident outside India. Detailed analysis and conclusion provided.

ITAT Confirms Reassessment & Section 68 Addition on Share Subscription

February 15, 2024 951 Views 1 comment Print

 ITAT Upholds Reassessment on Accommodation Entry Info from Investigation Wings & affirms Addition u/s 68 Due to Lack of Credibility Evidence in Share Subscription

ITAT Pune Remands Case for Fresh Assessment on Unexplained Investment

February 14, 2024 1164 Views 0 comment Print

In a recent ITAT Pune case, an assessee’s failure to prove the source of property investment leads to a call for reassessment. Read the full legal analysis and implications.

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