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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


Reopening of Assessment not permissible for Change of Opinion of AO

January 24, 2022 14367 Views 0 comment Print

Oracle Financial Services Software Limited Vs DCIT (Bombay High Court) Existence of the reason to believe that income chargeable to tax has escaped assessment is a jurisdictional condition for invoking the power under section 147 of the Act, 1961, both within and beyond a period of four years from the end of relevant assessment year. […]

Reassessment notice quashed for failure of AO to follow statutory formalities

January 21, 2022 3954 Views 0 comment Print

Reassessment notice was quashed with liberty to AO concerned to initiate fresh re-assessment proceedings in accordance with the relevant provisions of the Act as amended by Finance Act, 2021 and after making compliance of the formalities as required by the law.

Reopening of Assessment not permissible to take another view on same material

January 18, 2022 6435 Views 0 comment Print

Vodafone Idea Ltd. Vs ACIT (Bombay High Court) The entire basis for proposing to reopen, as can be seen from the reasons, is on the documents and submissions which were available before the Assessing Officer, before passing of the original assessment order. In fact, in the reasons, it is also recorded that the same issue […]

Calcutta HC Quashes Section 148 notices issued after 31.03.2021 in 1083 Cases

January 18, 2022 21954 Views 0 comment Print

Calcutta High Court Quashes Notices under Section 148 of Income Tax Act, 1961 which were Issued After 31st March 2021 in 1083 cases. Bagaria Properties and Investment Pvt. Ltd. & 1082 Anr. Vs. U.O.I & Ors.

Taxability of remuneration/interest not claimed by partnership firm in the hands of partners- HC Quashes assessment order

January 18, 2022 4212 Views 0 comment Print

Mamta Bhavesh Dave Vs ITO (Gujarat High Court) ITAT adjudicated the controversy as regards the deduction of remuneration/interest on the partners capital not claimed by the assessee i.e. the partnership firm in its profit and loss account. The Tribunal took notice of the fact that the CIT Appeals had directed to tax the amount of remuneration/interest […]

मुंबई हाईकोर्ट ने सीबीडीटी को लगाई फटकार, चेताया की अधिकारी करें अपने दिमाग का उपयोग

January 14, 2022 2778 Views 0 comment Print

हाल में ही मुंबई हाईकोर्ट ने आयकर संबंधित एक मामले में आयकर विभाग और उसको चलाने वाली संस्था सेंट्रल बोर्ड आफ डायरेक्ट टैक्सेस ( सीबीडीटी) को काफी खरी खरी सुनाई. कोर्ट ने इतना तक कह दिया कि सीबीडीटी अपने अधिकारियों को कम से कम इतनी ट्रेनिंग तो दें ताकि कोई केस निर्धारण करते समय अपने […]

Reopening of assessment not allowed for mere verification of claim

January 13, 2022 4062 Views 0 comment Print

For a mere verification of the claim, the power of re-opening of the assessment could not be exercised and it further held that AO under the guise of power to re-open the assessment cannot seek to undertake an undertaking a fishing or roving inquiry or seek to verify the claim as if he is the scrutiny officer.

High Court directs CBDT to formulate a scheme to train its officers; Passes strictures against AO, JCIT & PCIT

January 12, 2022 21252 Views 5 comments Print

Sharvah Multitrade Company Private Limited Vs ITO (Bombay High Court) Bombay High Court on non application of mind by AO while recording reasons as well as by PCIT while granting approval. Passes severe strictures against AO who recorded reasons for reopening, JCIT who recommended for approval and PCIT who granted approval. High Court Asks  CBDT […]

Delhi High Court dismisses 1,346 reassessment notices issued after March 31, 2021

January 7, 2022 6846 Views 0 comment Print

The Division bench of the High Court of Delhi in the case of Mon Mohan Kohli Vs Assistant Commissioner of Income Tax & Anr. quashed all reassessment notices on 15th Dec, 2021 issued by taxmen under the old regime on or after April 1, 2021, bringing in a huge relief for the taxpayers. They made […]

Section 148 notice issued to a dead assesse is notice without jurisdiction

January 4, 2022 1857 Views 0 comment Print

Arunaben Kanaiyalal Patel L/R of Late Kanaiyalal Dalsukh Patel Vs ACIT (Gujarat High Court) The subject matter of challenge in the present writ application is to the notice of reopening issued under Section 148 of the Act for the A.Y. 2017-18, essentially on the ground that the same is without jurisdiction as the impugned notice […]

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