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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 333 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 14058 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 2823 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 498 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 1053 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


Unaccounted sales must be taxed on net profit basis, not on gross profit

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 273 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 657 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 291 Views 0 comment Print

1439-day delay in Filing Appeal Condoned & Matter Remanded for Fresh Assessment: ITAT Kolkata

Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...

July 5, 2026 285 Views 0 comment Print

Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...

July 5, 2026 228 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 58938 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 6018 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 5985 Views 0 comment Print


U/s 153C Assessments Quashed – Mere Seized Material Not Enough Unless AO Shows Its Bearing on Total Income

May 18, 2026 759 Views 0 comment Print

The Tribunal ruled that the Revenue must establish a direct connection between seized material and the assessee’s taxable income before invoking Section 153C. Mechanical initiation of proceedings for multiple years was declared invalid.

Hyderabad ITAT Upholds Reopening Beyond 3 Years Though Final Addition Was Below ₹50 Lakhs – Jurisdiction Based on Reopening Information

May 18, 2026 357 Views 0 comment Print

The Tribunal held that validity of reopening under Section 148 must be tested on the basis of material available when reassessment proceedings are initiated. Subsequent reduction in additions does not invalidate jurisdiction already assumed.

Hyderabad ITAT Quashes AY 2015-16 Reopening – Notice u/s 148 Issued After 6 Years Held Time-Barred Despite ₹50 Lakh Escape Claim

May 18, 2026 417 Views 0 comment Print

Hyderabad ITAT held that a notice issued under Section 148 after six years from the end of AY 2015-16 was invalid. The Tribunal ruled that the amended 10-year reopening provision cannot revive already time-barred cases.

Chennai ITAT Quashes Reassessment – Notice u/s 148 Beyond 3 Years Needs PCCIT Approval, Not PCIT Approval

May 18, 2026 438 Views 0 comment Print

Chennai ITAT held that reassessment notices issued after three years must comply strictly with Section 151(ii) approval requirements. Failure to obtain sanction from the proper authority vitiated the entire reassessment proceedings.

ITAT Quashes Reassessment as AO Changed Reason from Fake Loan Entries to Penny Stock LTCG

May 17, 2026 3717 Views 0 comment Print

The ITAT Ahmedabad held that reassessment under Section 147 was invalid because the Assessing Officer reopened the case for fictitious loan entries but made additions for alleged bogus LTCG from penny stock transactions. The Tribunal ruled that changing the basis of reopening is not permissible in law.

Assessment Upheld as Material Seized in Search Can Be Used Even if Search Is Later Challenged

May 17, 2026 360 Views 0 comment Print

The Delhi High Court held that material recovered during a search can validly form the basis of reassessment proceedings even if the search is later alleged to be illegal. The Court ruled that proceedings initiated on the basis of such material do not automatically become void.

Kerala HC Upholds Rejection of Delayed Income Tax Refund Claim Due to Five-Year CBDT Limit

May 17, 2026 516 Views 0 comment Print

The Kerala High Court held that delay condonation applications under Section 119(2)(b) must comply with the revised five-year limitation prescribed by CBDT circulars. The Court ruled that authorities cannot entertain applications filed beyond the revised period.

Accrued Income Cannot Be Deferred Just Because Receipt Is Delayed – ITAT Upholds Taxability on Mercantile Basis

May 16, 2026 162 Views 0 comment Print

The Tribunal ruled that an assessee following mercantile accounting must offer interest income to tax on accrual basis, irrespective of delayed receipt. Failure to disclose the full accrued amount in the relevant year justified reassessment and addition.

Section 68 Addition Crashes – ITAT Mumbai Says Suspicion & Investigation Wing Reports Cannot Replace Evidence

May 16, 2026 258 Views 0 comment Print

ITAT Mumbai held that additions under section 68 cannot survive where the Assessing Officer failed to conduct independent verification of alleged accommodation entries. Reliance solely on third-party investigation reports was rejected.

ITAT Deletes Bogus Purchase Addition as No Evidence Linked Assessee to Alleged Accommodation Entries

May 15, 2026 1443 Views 0 comment Print

ITAT Ahmedabad held that reassessment under Section 147 was invalid as the Assessing Officer failed to show independent application of mind or establish a nexus between investigation material and escaped income.

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