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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


In case of violation of principles of natural justice, the availability of appellate remedy does not bar maintainability of writ petition

May 8, 2022 1983 Views 0 comment Print

When there is a violation of the principles of natural justice, the availability of an appellate remedy does not bar the maintainability of a writ petition.

SC Judgment on Section 148 Notices – Using Missile where Rifle could have sufficed

May 8, 2022 3519 Views 0 comment Print

Analysis of the recent Supreme Court judgment on Section 148 Notices. Find out if the court used excessive force when a simpler approach would have sufficed.

Way ahead in reassessment after Supreme Court decision

May 8, 2022 7008 Views 0 comment Print

Understanding the Supreme Court’s decision on reassessment after the amendment. Learn about the rights of the Revenue and Assessees in this legal controversy.

Reincarnation of Section 148 Reassessments Notices issued post 01/04/2021

May 8, 2022 12867 Views 0 comment Print

Learn about the impact of the Finance Act 2021 on reassessment notices and the validity of unamended Act notices issued post 01/04/2021.

Section148 Notices not become invalid merely for issue under old law: SC

May 7, 2022 4311 Views 0 comment Print

SC rules that Section148 Notices issued under old law remain valid. Taxpayers cannot use change in law as an excuse to escape proceedings.

HC direct Tax dept to maintain judicial discipline & follow doctrine of binding precedent

May 7, 2022 3522 Views 0 comment Print

HC direct the respondents to maintain judicial discipline and follow the doctrine of binding precedent and be careful in future, having due regard to the authorities of the Court, keeping in mind the judicial propriety and discipline.

Reopening cannot be proposed on the basis of change of opinion

May 7, 2022 795 Views 0 comment Print

Lokhandwala Construction Industries Private Limited Vs DCIT (Bombay High Court) Once a query is raised during assessment proceedings and assessee has replied to it, it follows that the query raised was a subject matter of consideration of the Assessing Officer while completing the assessment. It is not necessary that an assessment order should contain reference […]

HC imposes cost of Rs. 5000 for delayed filing of writ against section 148 Notice 

May 7, 2022 783 Views 0 comment Print

Orion Book Binders Private Limited Vs ITO (Calcutta High Court) HC held that writ petition is allowed subject to payment of costs of Rs.5,000/- to the Calcutta High Court Bar Association Lawyers’ Benevolent Fund, since the impugned notice under section 148 of the Income Tax Act, 1961 has been issued on April 8, 2021 as […]

Reassessment notice invalid if it is merely based on Investigation Wing information

May 6, 2022 3939 Views 0 comment Print

Sandipkumar Parsottambhai Patel Vs ITO (ITAT Surat) We note that in assessees case, the assessing officer received information from the Investigation Wing, Kolkata who had carried out survey / search operations wherein it was established that in large number of penny stock companies share prices were artificially raised/manipulated on the Stock Exchanges in order to […]

New Timelines for Validity of Old Section 148 Reassessment Notices as per SC Judgement 

May 6, 2022 12783 Views 0 comment Print

Author has tried to capture all the nuances and practical implications of the Hon’ble Supreme Court judgement on Validity of Old 148 Re-Assessment Notices, and gives a Clear and Unambiguous Picture & Guidance on the New Valid Timelines for Validity of such impugned Re-assessment Notices, in accordance with the directions given in the SC judgement.

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