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Section 148

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ITAT Deletes On-Money Addition as Unsigned Agreement & Third-Party Records Lacked Evidence

Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...

June 30, 2026 333 Views 0 comment Print

Rectification, Assessment and Appeal under Income Act, 1961

Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...

June 29, 2026 14058 Views 0 comment Print

Can Updated Return Be Filed After Notice Under Sections 143(2), 148A or 148?

Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...

June 27, 2026 2823 Views 0 comment Print

SC Sends JAO vs Faceless Reassessment Dispute Back to High Courts

Income Tax : The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leavi...

June 27, 2026 498 Views 0 comment Print

Appellate Kill Shot to Reassessment Notices Under Section 148/148A

Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...

June 20, 2026 1053 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 2469 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 4584 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 6918 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 7524 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 13395 Views 0 comment Print


Latest Judiciary


Unaccounted sales must be taxed on net profit basis, not on gross profit

Income Tax : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...

July 7, 2026 282 Views 0 comment Print

Section 56(2)(x) Applicability Depends on Agreement Date; Mistaken Tax Payment Refundable: ITAT Mumbai

Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...

July 6, 2026 657 Views 0 comment Print

APMC Commission Agent Not Taxable on Entire Sale Proceeds; Section 69A Issue Remanded: ITAT Bengaluru

Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...

July 6, 2026 291 Views 0 comment Print

1439-day delay in Filing Appeal Condoned & Matter Remanded for Fresh Assessment: ITAT Kolkata

Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...

July 5, 2026 285 Views 0 comment Print

Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...

July 5, 2026 228 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 1272 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 5961 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 58938 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 6018 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 5985 Views 0 comment Print


Penny Stock Loss Addition deleted in absence of Share Price Manipulation Evidence

May 15, 2026 552 Views 0 comment Print

Kolkata ITAT upheld deletion of addition relating to alleged bogus penny stock loss after finding that the assessee had furnished contract notes, demat records, broker statements, and bank documents supporting the transactions.

Reassessment Notice Quashed as Revenue Failed to Establish Link Between Assessee & Seized Material

May 14, 2026 537 Views 0 comment Print

Court held that there was no direct or indirect connection between the assessee and the handwritten inquiry register relied upon by the department. Statements recorded during search proceedings also did not mention the assessee.

ITAT Sends Back Bogus Purchase & Cash Credit Additions for Fresh Decision

May 14, 2026 510 Views 0 comment Print

ITAT Surat restored reassessment appeals to the CIT(A) after observing that the assessee should receive one final opportunity to present evidence. The Tribunal imposed costs due to partial compliance before the appellate authority.

DSIR Approval Binding: ITAT Allows Section 35(2AB) Deduction for R&D Expenses

May 14, 2026 360 Views 0 comment Print

Tribunal ruled that once DSIR certifies R&D expenditure under Section 35(2AB), the Assessing Officer cannot disregard the claim without following the statutory procedure. The decision reinforces the importance of DSIR certification in weighted deduction disputes.

WhatsApp Chats Alone Cannot Justify Section 69A Addition for Jewellery Purchases: ITAT Delhi

May 14, 2026 3315 Views 0 comment Print

The Delhi ITAT held that informal WhatsApp conversations without corroborative evidence cannot establish unexplained investment under Section 69A. Since no excess jewellery, invoices, or payment proof were found, the addition was deleted.

Form 16 Trap: ITAT Deletes ₹51 Lakh Penalty on Wrong ESOP Exemption Claim

May 13, 2026 780 Views 0 comment Print

The Bangalore ITAT held that an assessee claiming exemption based on Form 16 issued by the employer acted under a bona fide belief and cannot automatically be penalized for misreporting. The Tribunal deleted the ₹51.20 lakh penalty levied under Section 270A.

Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

May 13, 2026 621 Views 0 comment Print

ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-examine the person whose statement forms the basis of the assessment. The Tribunal ruled that reliance on such untested statements violates principles of natural justice and renders the addition legally unsustainable.

Pune ITAT Quashes Section 148 Notice for Taking Sanction From PCIT Instead of PCCIT

May 13, 2026 816 Views 0 comment Print

The Pune ITAT held that reassessment proceedings become void when approval under Section 151 is taken from the wrong authority. Since sanction was obtained from the PCIT instead of the PCCIT, the notice under Section 148 was quashed.

No Fishing Enquiries in Reassessment – Pune ITAT Quashes 148 Proceedings After AO Dropped Original Issue!

May 13, 2026 462 Views 0 comment Print

Pune ITAT held that once the Assessing Officer accepted the explanation for cash deposits, reassessment could not continue on a completely new issue without issuing a fresh notice under Section 148.

No Cross-Examination, No Addition: ITAT Deletes ₹1.09 Crore “Entry Operator” Loan Addition

May 12, 2026 507 Views 0 comment Print

ITAT Mumbai held that addition under Section 69A could not survive when based solely on a third-party statement without granting cross-examination. The Tribunal ruled that denial of cross-examination violated principles of natural justice.

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