#Section 148
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Jurisdictional Condition Must Be Satisfied to Justify Notice for Reopening

Bombay HC lays guidelines on reopening cases for AO for strict compliance

Reopening on review of same material considered in original assessment invalid

Issue of Section 148 notice on non-existing entity is not a curable mistake

Reopening notice invalid in absence of any tangible material to establish escapement of income for assessment

AO not entitled on change of opinion to commence reassessment proceedings

AO cannot reopen an assessment even within a period of 4 years merely on the basis of a change of opinion

Review in the garb of reassessment is absolutely prohibited

HC surprised with reasons recorded for reopening & hoped for better reasons

HC dismisses Reassessment Notice to Tata Sons Based on mere change of opinion

Section 148 Notice can be issued as per law prevalent on issue date

Reason recorded are without application of mind if for similar reasons no addition been made in earlier Assessment Year

Amendment in Income Tax assessment & reassessment provisions

No provision in law to tax income which Assessee could have earned but not earned
Explore the latest Section 148 updates on TaxGuru, including relevant Income-tax Act provisions, rules, notifications, circulars, judicial decisions and compliance guidance. The coverage highlights important tax positions, procedural requirements, assessments, deductions, penalties and litigation developments to help taxpayers and professionals understand the practical implications of changes in income-tax law.
