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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 759 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 105 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 333 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 780 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 699 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 195 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


ITAT Pune: Entire Bank Deposits Cannot Be Taxed – Income to Be Estimated @2% on Deposits in Renukamata Society Account

March 13, 2026 741 Views 0 comment Print

The Tribunal held that entire bank deposits cannot automatically be treated as unexplained income under Section 69A. Instead, where deposits relate to commission-based transactions, only a reasonable profit percentage (2% of deposits) should be taxed.

CIT(A) Cannot Admit Fresh Evidence Without AO’s Opportunity – Violation of Rule 46A; Matter Remanded

March 13, 2026 303 Views 0 comment Print

The Tribunal ruled that admitting additional evidence without seeking a remand report from the Assessing Officer breaches Rule 46A. The matter was sent back to the AO for reconsideration after examining the evidence.

Reassessment Quashed – Notice U/s 148A(b) Invalid for Granting Less Than Mandatory 7 Days to Reply

March 13, 2026 774 Views 0 comment Print

The Tribunal ruled that Section 148A(b) requires a minimum of seven days for the assessee to respond. Failure to grant this statutory period renders the notice and subsequent reassessment proceedings illegal.

Additions Cannot Survive When Reassessment Is Quashed by High Court – Revenue’s Appeal Dismissed

March 13, 2026 303 Views 0 comment Print

The Tribunal held that once the High Court quashed the reassessment for being based on a change of opinion, the additions made in those proceedings could not survive.

Reassessment Quashed as Time-Barred – Fresh Notice U/s 148 Issued Beyond Surviving Period After Ashish Agarwal Judgment

March 13, 2026 606 Views 0 comment Print

The Tribunal found that the Assessing Officer failed to issue the fresh notice within the surviving limitation period recognized by the Supreme Court. The reassessment order was therefore quashed.

Reassessment Quashed – Mechanical Approval U/s 151 Based on Wrong Fact that Assessee Was a Non-Filer

March 13, 2026 504 Views 0 comment Print

ITAT Bangalore held that reassessment proceedings were invalid where approval under Section 151 was granted mechanically. The sanction was based on the incorrect assumption that the assessee had not filed a return.

ITAT Chennai Quashes U/s 153A Additions Based Only on Special Audit Findings

March 13, 2026 279 Views 0 comment Print

The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.

Assessment in the Name of Deceased Person – Absence of Notice to Legal Heir – Entire Assessment Held Void: ITAT Bangalore

March 12, 2026 4884 Views 0 comment Print

Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.

Advance Tax Condition u/s 249(4)(b) Applies Only to Admitted Income: ITAT Chennai

March 11, 2026 468 Views 0 comment Print

ITAT held that the appellate authority wrongly dismissed the appeal under Section 249(4)(b) as there was no advance tax liability under Section 209. The matter was remanded for fresh adjudication on merits.

Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

March 11, 2026 1866 Views 0 comment Print

Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. Inordinate delay in recording the satisfaction note can lead to the proceedings being quashed as time-barred.

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