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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


Section 68 Addition Cannot Be Sustained When Loans Are Received and Repaid Through Banking Channels

March 10, 2026 7239 Views 0 comment Print

ITAT Delhi deleted additions under Sections 68 and 69C after finding that the assessee received and repaid loans through banking channels with supporting confirmations and evidence.

Reassessment Notice Upheld Because AO Followed CBDT and SC Directions

March 9, 2026 489 Views 0 comment Print

ITAT held that the reassessment notice issued under Section 148 was valid because the Assessing Officer followed CBDT Instruction 1/2022 and the Supreme Court’s decision on reassessment procedures. The Tribunal rejected the argument that the notice was barred by limitation.

Reassessment Notice Invalid as It Was Issued to Non-Existent Entity: Bombay HC

March 9, 2026 417 Views 0 comment Print

The Bombay High Court quashed reassessment proceedings for AY 2018-19 after finding that the notice under Section 148 was issued in the name of an entity that had already merged and ceased to exist.

Reassessment Notice Quashed Because It Was Issued Beyond Limitation: Bombay HC

March 9, 2026 729 Views 0 comment Print

The Bombay High Court held that the reassessment notice under Section 148 was issued after the surviving limitation period expired. As a result, the entire reassessment proceedings and assessment order were quashed.

TDS Default Order Time-Barred as Limitation Must Be Computed Quarter-Wise, Not Annually

March 9, 2026 537 Views 0 comment Print

The Bombay High Court ruled that limitation under Section 201(3) must be calculated based on the financial year in which each quarterly TDS statement is filed. The decision confirms that annual or cumulative computation of limitation is not permitted.

Parallel Assessment Proceedings Illegal, ITAT Quashes Reassessment Order in Case of Lalit Modi

March 9, 2026 828 Views 0 comment Print

ITAT Delhi held that reassessment proceedings under Section 147 cannot be initiated while scrutiny assessment under Section 143(2) is still pending. Such parallel proceedings are without jurisdiction and render the entire reassessment order invalid.

Reassessment Quashed as Section 148 Notice Was Issued by JAO Instead of FAO

March 8, 2026 1197 Views 0 comment Print

ITAT Hyderabad held that reassessment proceedings were invalid because the notice under Section 148 was issued by the jurisdictional officer rather than through the mandatory faceless system. The assessment order was quashed for lack of jurisdiction.

Reassessment Quashed Because Notice Issued to Non-Existent Company After LLP Conversion

March 8, 2026 783 Views 0 comment Print

ITAT Delhi held that reassessment proceedings are invalid when notice under Section 148 is issued in the name of a company that had already converted into an LLP. The Tribunal ruled that proceedings against a non-existent entity are void in law.

Penalty U/s 270A Set Aside as U/s 270AA Immunity Denied Due to Form 68 Glitch – ITAT Remands Case

March 7, 2026 1269 Views 0 comment Print

The Tribunal held that immunity under Section 270AA cannot be denied due to technical issues in filing Form 68. The penalty under Section 270A was set aside and the matter was remanded for reconsideration.

Reassessment Notice Issued to Deceased Person Invalid – Entire Proceedings u/s 147 Quashed – ITAT Bangalore

March 7, 2026 693 Views 0 comment Print

The Tribunal ruled that reassessment proceedings initiated against a dead person are void in law. A valid notice must be issued to the legal heirs under Section 159 before initiating reassessment.

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