#Section 148
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Mere change of opinion not valid for reopening of assessment u/s 148

Invocation of jurisdiction u/s 263 on same subject which was duly verified in reassessment proceeding unjustified

No reassessment for Assessment years 2013-14 & 2014-15 if notices issued under old provision between 01.04.2021 to 30.06.2021

The New intercontinental ballistic missile of Income Tax Department

Original assessment completed after considering all facts hence re-assessment unsustainable

Borrowed Satisfaction & Necessity of Providing Material to Assessee before Reopening An Assessment

Extended time under TOLA not available for Sanction by Specified Authority U/S 151

Reopening by merely quoting Insight portal information is invalid

Draft submission regarding approval u/s 151 from competent authority for issue of notice u/s 148

Payment of IUC Charges is not “Fee for Technical Services” or “Royalty”

Authorized signatory of cheque, not being drawer, cannot be directed to pay interim compensation

Reassessment only because of difference in opinion of valuation as adopted by assessee is untenable

Reassessment proceedings without any new tangible material is unsustainable in law

Another Reassessment Notice Cannot be Issued by AO for Same AY
Explore the latest Section 148 updates on TaxGuru, including relevant Income-tax Act provisions, rules, notifications, circulars, judicial decisions and compliance guidance. The coverage highlights important tax positions, procedural requirements, assessments, deductions, penalties and litigation developments to help taxpayers and professionals understand the practical implications of changes in income-tax law.
