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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 222 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


AO cannot calculate cost of acquisition on the basis of his own assumption

November 17, 2022 1506 Views 0 comment Print

Assessing authority had passed the order beyond his jurisdiction by calculating the cost of acquisition on basis of his own assumption.

Change of opinion not base for reassessment proceedings

November 14, 2022 1062 Views 0 comment Print

Delhi high court held that there was no new/ fresh material before AO to initiate reassessment proceedings, accordingly, mere change of opinion cannot form the basis for initiating reassessment proceedings

Reopening of assessment u/s 148 based on old information is invalid

November 8, 2022 4824 Views 0 comment Print

ITAT Kolkata held that original assessment was made under section 143(3)/147, i.e. scrutiny assessments. Further, there was no fresh information available with the revenue. Hence, reopening of assessments relying on the same information is invalid.

Reassessment based on same material examined in regular assessment is erred in law

November 7, 2022 2064 Views 0 comment Print

Gujarat High Court held that change of opinion on the part of the Assessing Officer acting on the same material which was examined by him in the regular assessment is erred in law.

Section 148A(b) requires grant of minimum 7 days to file reply to show cause notice

November 6, 2022 9660 Views 0 comment Print

Delhi High Court in Shri Sai Co-operative Thrift and Credit Society Ltd. (supra) has considered a similar position and has held that issuance of a show cause notice with a period lesser than seven days would vitiate the same.

HC Sets Aside section 148A(d) order for not considering Reply of Petitioner

November 4, 2022 714 Views 0 comment Print

Agriculture Produce Market Committee Vs ITO (Bombay High Court) It is observed that reply filed by the petitioner to the notice has not been taken into consideration especially in view of the fact that such reply was filed on 31.03.2022 and on the same day the impugned order came to be passed on 10.41 p.m. […]

Writ cannot be filed against sufficiency or adequacy of reasons for Income Tax Reassessment

November 4, 2022 603 Views 0 comment Print

Pramod Kumar Vs ACIT (Telangana High Court) HC is of the view that present is not a fit case to interdict the proceedings at the very threshold. Reasons have been assigned by the assessing officer as to why the explanation given by the petitioner could not be accepted. Certainly, such reasons given have a nexus […]

Re-assessment proceedings against non-existent entity – HC remands matter back to AO

November 3, 2022 714 Views 0 comment Print

Re-assessment proceedings were sought to be initiated against a non-existent company as it had amalgamated with Petitioner and income of assessee had already been accounted for in books of accounts of Petitioner.

Reopening u/s 148 justified as assessment order suffered from non-application of mind

November 2, 2022 1545 Views 0 comment Print

ITAT Delhi held that assessment order suffered from non-application of mind and also overt omission and failure on the part of the assessee to disclose fully and truly all material facts as were necessary for the assessment. Accordingly, reopening of assessment u/s 148 justified.

HC upheld re-assessment proceeding against alleged bogus LTCG

October 28, 2022 2130 Views 0 comment Print

Vikas Jain Vs ITO (Delhi High Court) In view of the report of DDIT (Inv.) Unit-7(1) and 7(3) Mumbai, shared with the AO which suggests that the LTCG earned by the petitioner in AY 2014-15 was bogus and since, the said LTCG was claimed as exempt income, the AO at this stage, concluded that the […]

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