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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 762 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 108 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 339 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 783 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 702 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 219 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


No Section 271(1)(c) Penalty if no Variation in Returned & Assessable Income

July 22, 2023 10056 Views 0 comment Print

ITAT has held in the case of Meera Anirudha Mirgunde Vs ITO that when there is no variation in the returned and assessable income, penalty under section 271(1)(c) of the Income Tax Act is not leviable.

No reassessment of Completed/Unabated Assessments Without Incriminating Material: SC

July 22, 2023 4032 Views 0 comment Print

The Supreme Court’s ruling sets a precedent on reassessment proceedings, stating no action will be taken on completed or unabated assessments without incriminating material.

Reopening of assessment u/s 148 for mere change of opinion is unsustainable

July 21, 2023 1872 Views 0 comment Print

Bombay High Court held re-opening of assessment under section 148 of the Income Tax Act for mere change of opinion is without jurisdiction and unsustainable in law.

Order passed u/s 148A(d) within 3 years needs approval from PCIT & not PCCIT

July 21, 2023 2709 Views 0 comment Print

Calcutta High Court held that considering the provisions, order passed u/s 148A(d) is within three years and accordingly, Principal CIT (PCIT) and not the Principal Chief CIT (PCCIT) is ‘Specified Authority’ for approval of the same. Thus, AO rightly took approval from Principal CIT.

Penalty u/s 271B not leviable for venial technical breach without mala fide intention

July 21, 2023 1107 Views 0 comment Print

ITAT Chennai held that penalty under section 271B of the Income Tax Act cannot be levied for venial technical breach without any mala fide intention of the assessee as tax audit report submitted before completion of assessment proceedings.

Absence of Valid Notice u/s. 143(2): ITAT quashes Assessment Proceedings

July 21, 2023 6165 Views 0 comment Print

Analysis of Jigna Chetan Mehta Vs ACIT case about the validity of assessment proceedings in absence of a proper notice under section 143(2) of IT Act.

ITAT Quashes Reassessment Order Due to Non-Issue of Notice

July 21, 2023 1128 Views 0 comment Print

Discover the case of Sohanbir Sing Vs Assessing Officer, where the ITAT Delhi ruled that failure to issue notice for reassessment cannot be remedied under Section 292B of the Income Tax Act.

Reassessment Proceedings Invalid Without New Tangible Material

July 20, 2023 981 Views 0 comment Print

Explore the ITAT Chennai ruling in the V.K. Sasikala vs DCIT case, where the importance of tangible new material in reassessment proceedings has been underscored. Learn how the tribunal’s decision impacts the treatment of reassessment cases in Indian Tax Law.

Unsustainable Addition u/s 68: Assessee Discharges Onus, Revenue Fails

July 20, 2023 828 Views 0 comment Print

ITAT Chennai held that once the assessee has discharged its primary onus of fulfilling the three ingredients of section 68 of the Income Tax Act, the further onus was on revenue to make further enquiry. However, since the onus lying on the revenue was not discharged, addition u/s 68 couldn’t be sustained.

Reasons for reopening not provided – ITAT upholds quashing of order by CIT(A)

July 19, 2023 2400 Views 0 comment Print

A deep dive into the significant ruling of ITAT Mumbai in ITO Vs Asahi Infrastructure Projects Ltd case, exploring the issues related to the reopening of the assessment and non-genuine purchases, as per the guidelines set in the landmark GKN Driveshaft case.

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