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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 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


Section 148 | Writ Court Cannot Interfere at Notice stage if AO followed due procedures

August 4, 2022 3219 Views 0 comment Print

Midland Microfin Ltd. Vs Union of India and others (Punjab and Haryana High Court) Whether at this stage of notice under Section 148, writ Court should venture into the merits of the controversy when AO is yet to frame assessment/reassemment in discharge of statutory duty casted upon him under Section 147 of the Act Admittedly […]

No addition for bogus purchase on borrowed satisfaction from VAT Dept. without proper examination

August 4, 2022 2070 Views 0 comment Print

Addition of bogus purchase by AO was not justified on borrowed satisfaction from the Value added tax (VAT) department without proper cross-verification.

Proceedings for A.Y 2013-14 & 2014-15 cannot be reopened beyond 4 years

August 3, 2022 7107 Views 2 comments Print

Understanding the time limit for reopening proceedings for A.Y 2013-14 & 2014-15 under the old provisions. Learn the implications and exceptions.

HC quashed Reopening for Bogus Purchase when no evidence furnished to Appellant

August 3, 2022 2358 Views 0 comment Print

Best Buildwell Private Limited VS ITO (Delhi High Court) The show cause notice primarily states that ‘it is seen that the Petitioner has made purchases from certain non-filers’. However no details or any information of these entities was provided to the Petitioner. It is not understood as to how the Petitioner was to know which […]

Usurpation of jurisdiction by AO to reopen assessment is legally untenable

August 1, 2022 621 Views 0 comment Print

Srijal Gupta Vs ITO (ITAT Amritsar) After a thoughtful observation of the fact of the case we decided that the reopening was made u/s. 148 related to purchase of property amount to Rs.9,53,750/-. But after completion of assessment, the ld. AO had accepted the assessee’s investment and had not added any amount related to source […]

Revised Guideline for Issue of Section 148 Notice

August 1, 2022 91977 Views 1 comment Print

Salient features of new Section 148 to 151A ‘i.e. assessment/reassessment procedure of Income Escaping Assessment

Reopening based on tangible material is valid if Assessee not filed Income Tax Return

July 31, 2022 768 Views 0 comment Print

Roop Raj Hospitality (P) Ltd Vs ITO (ITAT Delhi) Admittedly, in the present appeal, the assessee has not raised any ground on merits challenging the addition sustained by learned Commissioner (Appeals). On a query from the Bench, learned counsel appearing for the assessee submitted that assessee has accepted the addition sustained by learned Commissioner (Appeals). […]

Power under Section 148 not excluded due to exercise of appellate jurisdiction

July 31, 2022 1572 Views 0 comment Print

Sunil Jain Vs Income Tax Department (Delhi High Court) HC Court is also of the opinion that just because the Appellate Authority has the power to modify an assessment order with regard to a source of income that has not been considered during assessment proceedings does not mean that the jurisdiction of the authorities under […]

Reopening of assessment based on mechanically received approval is bad in law

July 29, 2022 2334 Views 0 comment Print

Held that reopening of assessment on the basis of the approval given in mechanical manner without application of mind is bad in law and liable to be quashed.

Request to amend section 151 Sanctioning Authority for reassessment

July 25, 2022 6882 Views 0 comment Print

Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 148/148A w.e.f. 1st April, 2021 DIRECT TAXES PROFESSIONALS’ ASSOCIATION Income Tax Building, 3, Govt. Place West, Ground Floor, Kolkata 700001 Ph – 033-22420638 URGENT Ref. No. DTPA/Rep/22-23/ | Dated: 25th July, 2022 To, Smt. […]

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