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Section 148

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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


Reassessment proceedings without any new tangible material is unsustainable in law

March 25, 2023 1299 Views 0 comment Print

Bombay High Court held that re-assessment proceedings, in absence of any failure to disclose any material fact and without any new tangible material which was not available at the time of passing of the original assessment order, is unsustainable.

Another Reassessment Notice Cannot be Issued by AO for Same AY

March 25, 2023 11103 Views 0 comment Print

As per Section 147 of the Income Tax Act, 1961, the Income Tax Department has the power to reassess an individual’s previously filed income tax returns. The Assessing Officer can pick income tax return for reassessment subject to some pre-defined criteria by sending a notice under section 148 for income Escaping Assessment.

Reasons for reopening found to be non-existent, such defect is not curable by applying section 292B

March 24, 2023 2487 Views 0 comment Print

ITAT Delhi held that AO drew belief on the reasons which were later found to be totally non-existent. Such defect in the reasons cannot be ascribed as a mere technical irregularity and consequently defect cannot be cured by applying Section 292B of the Income Tax Act.

Reassessment proceedings invalid as no failure in disclosing any material facts

March 24, 2023 1950 Views 0 comment Print

Bombay High Court held that initiation of reassessment proceedings invalid as there was no failure on the part of the assesse to disclose any material facts.

Section 148 of Income Tax Act 1961: Notice and Reply

March 23, 2023 89370 Views 2 comments Print

Navigate Section 148 of the Income Tax Act 1961 with insights on notice issuance, how to respond, and consequences of non-response. Stay informed about timelines, reply procedures, and potential penalties. Expert guidance on understanding and complying with this crucial tax provision.

Draft submissions regarding reasons recorded u/s 148(2) of Income Tax Act, 1961

March 18, 2023 5181 Views 0 comment Print

Draft submissions regarding reasons recorded u/s 148(2) of the Income Tax Act, 1961 provide detailed insights into the legal implications of notice issuance and the necessity of furnishing reasons to the assessee. These submissions, accompanied by relevant case law, highlight the importance of procedural compliance and the consequences of non-compliance, aiming to ensure fair and just assessment proceedings.

Initiation of reassessment proceeding by mere putting a seal as approving statement not sufficient

March 18, 2023 1254 Views 0 comment Print

ITAT Delhi held that by mere putting a seal as approving statement is not sufficient for initiation of reassessment proceedings u/s 147. It proves that approving authority has granted the approval in mechanical manner without application of mind and hence initiation of reassessment proceedings invalid.

Reference to DVO for correct fair market value mandatory if requested by assessee

March 16, 2023 5466 Views 0 comment Print

ITAT Mumbai held that even after request from assessee to refer DVO for correct fair market value of the subject property, AO was duty-bound to refer the same to DVO. Accordingly, matter remanded back with a direction to refer the matter to DVO and decide the issue.

Interest on instalments refunded under IDS 2016 not payable as it was not voluntary tax payment

March 15, 2023 1086 Views 0 comment Print

Jharkhand High Court held that instalments paid under Income Declaration Scheme, 2016 is allowed as refund. However, interest on the same is not payable as there was no voluntary payment of tax on self-assessment.

Draft submission – Section 148 notice sent at wrong address

March 15, 2023 5304 Views 0 comment Print

In draft submissions before the First Appellate Authority, challenge the issuance of a Section 148 notice sent to the wrong address, affecting the assessment proceedings.

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