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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


Delhi HC stays Section 148 Proceedings in 42 cases

August 14, 2021 5061 Views 0 comment Print

SG Corporation Joint Venture Vs ITO & Ors. (Delhi High Court) 1. The respondents are restrained from continuing with the reassessment proceedings, in any manner, pursuant to the impugned notices. 2. No adjournment shall be granted on the next date of hearing. FULL TEXT OF THE HIGH COURT ORDER /JUDGEMENT On 13th July, 2021, this […]

Reassessment after 4 year invalid if assessee disclosed all material facts during original assessment

August 13, 2021 1206 Views 0 comment Print

CIT Vs Mr. John Ettimootil Samuel (Madras High Court) 1. Sets aside reassessment framed u/s 147 after expiry of four years of assessment u/s 143(3), holding that the assessee had disclosed all material facts in the original assessment qua consideration and deemed consideration u/s 50C of the Act. 2. The Tribunal was fully justified in […]

No penalty u/s 271(1)(c) when returned income accepted filed in response to notice u/s 148

August 12, 2021 32604 Views 4 comments Print

In the case of the assessee at present no finding was recorded in the assessment order that there was concealment of income.The assessee has not furnished inaccurate particulars of its income.True income of the assesseee was declared in the return filed by the assessee after issue of the notice u/ s 148 of the act . And the case of the assessee was made u/s 143(3) of the act on the same returned income.

Reopening Quashed when Supplied & Recorded Reasons are Not Same & Verbatim

August 12, 2021 2628 Views 0 comment Print

Jansampark Advertising & Marketing P. Ltd. Vs ITO (ITAT Delhi) Settled position of law as held by the Hon’ble High Court in the case of Haryana Acrylic Manufacturing Co. v. Commissioner of Income Tax 308 ITR 38 [ Delhi] is that the requirement of recording the reasons, communicating the same to the assessee, enabling the […]

Assessment Based On Change of Opinion Is Void Ab Initio

August 10, 2021 1755 Views 0 comment Print

SJM International Ltd. Vs DCIT (ITAT Delhi) The conclusion of the Assessing Officer at the end of the reasons recorded as noted above is contradictory. In the first two lines, the Assessing Officer has recorded the finding that the sum of Rs.2,35,00,000/- has escaped assessment but in the last two lines, he has recorded that […]

ITAT Quashes Reassessment on Multiplicity of Errors In Reasons

August 9, 2021 1500 Views 0 comment Print

Lakhmi Chand Tejoo Mal Vs ACIT (ITAT Delhi) MULTIPLICITY OF ERRORS IN REASONS MAKE REASSESSMENT VOID  The ld. counsel for the assessee vehemently stated that 11 entries have been shown in the information and it can be seen that there are repetition of same entries/amounts and the Assessing Officer has, in fact, at para -6 […]

Lack of fresh tangible material invalidates reopening when details already given in regular assessment

August 8, 2021 1737 Views 0 comment Print

ACIT Vs Sahyog Infrastructure Pvt. Ltd (ITAT Delhi) Based on the above reasons recorded, notice under Section 148 of the act was issued to the assessee on 25th of June, 2013. From the above reasons recorded it is evident that all these documents were available with the ld. Assessing Officer at the time of making […]

Delhi HC ruling on validity of 19 notices under section 148(1)

August 2, 2021 5019 Views 0 comment Print

Ajay Mittal Vs ACIT (Delhi High Court) Hon’ble Delhi High Court on validity of 19 notices issued u/s 148(1) of the Income Tax Act, 1961 restraining the Revenue from continuing with the reassessment proceedings, in any manner, pursuant to the impugned notices. FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT 1. On 13th July, 2021, this […]

HC stays section 148 notice issued without complying section 148A

August 2, 2021 3690 Views 0 comment Print

Bhagwati Prasad Jalan Vs  Union Of India And Ors. (Calcutta High Court) The learned Advocate for the respondents is not able to deny the allegations of the petitioners that Section 148A provisions of the Income Tax Act, 1961 was not complied with in this case before issuing notice under Section 148 of the said Act and […]

Assessment order valid despite initial section 147 notices in wrong name if revenue identifies & corrects the mistake

August 1, 2021 4326 Views 0 comment Print

Principal Officer, M/s. Vedanta Limited Vs DCIT (Madras High Court) As far as the present Writ Petition is concerned, admittedly, the notice under Section 148 was issued in a wrong name. However, close reading of the name of the Company would reveal that the first word ‘Sesa’ is not alien to the petitioner Company and […]

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