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Section 148

Latest Articles


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 339 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 14064 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 2853 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 507 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 1056 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


Section 43CA Inapplicable to AY 2013-14; Reopening Quashed: Bombay HC

Income Tax : Bombay HC quashed Section 148 reopening for AY 2013-14, holding Section 43CA was inapplicable and stamp duty valuation alone could...

July 8, 2026 99 Views 0 comment Print

Section 148 Notice Quashed for Vague Reasons & Lack of Supporting Material: ITAT Pune

Income Tax : ITAT Pune quashed a Section 148 notice based on vague information and directed deletion of a ₹51.35 lakh addition for lack of su...

July 8, 2026 102 Views 0 comment Print

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

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 456 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 1110 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 315 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 58977 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 6021 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 5991 Views 0 comment Print


Writ cannot be filed against sufficiency or adequacy of reasons for Income Tax Reassessment

November 4, 2022 645 Views 0 comment Print

Pramod Kumar Vs ACIT (Telangana High Court) HC is of the view that present is not a fit case to interdict the proceedings at the very threshold. Reasons have been assigned by the assessing officer as to why the explanation given by the petitioner could not be accepted. Certainly, such reasons given have a nexus […]

Re-assessment proceedings against non-existent entity – HC remands matter back to AO

November 3, 2022 741 Views 0 comment Print

Re-assessment proceedings were sought to be initiated against a non-existent company as it had amalgamated with Petitioner and income of assessee had already been accounted for in books of accounts of Petitioner.

Reopening u/s 148 justified as assessment order suffered from non-application of mind

November 2, 2022 1602 Views 0 comment Print

ITAT Delhi held that assessment order suffered from non-application of mind and also overt omission and failure on the part of the assessee to disclose fully and truly all material facts as were necessary for the assessment. Accordingly, reopening of assessment u/s 148 justified.

HC upheld re-assessment proceeding against alleged bogus LTCG

October 28, 2022 2205 Views 0 comment Print

Vikas Jain Vs ITO (Delhi High Court) In view of the report of DDIT (Inv.) Unit-7(1) and 7(3) Mumbai, shared with the AO which suggests that the LTCG earned by the petitioner in AY 2014-15 was bogus and since, the said LTCG was claimed as exempt income, the AO at this stage, concluded that the […]

Disclosure before criminal investigation wing cannot be treated as disclosure’ before assessing officer in assessment

October 26, 2022 1110 Views 0 comment Print

RKR. Gold P. Ltd Vs ACIT (Madras High Court) The criminal investigation wing is separate and distinct from the assessment wing and disclosure made before one wing will not exonerate the petitioner from the requirement of making a ‘full and true disclosure’ before the assessing officer in assessment. In fact, the apparent difference in the […]

Missing foundational allegation in Section 148A(b) notice cannot be incorporated by issuing a supplementary notice

October 24, 2022 2997 Views 0 comment Print

If foundational allegation is missing in notice issued under Section 148A(b) , the same cannot be incorporated by issuing a supplementary notice.

Review of order, on same set of facts & material, is impermissible

October 24, 2022 621 Views 0 comment Print

ACIT Vs Joseph Selvakumar Selvan (ITAT Chennai) Upon careful consideration, it could be gathered that the return of income was already scrutinized u/s 143(3) and the issue of computation of capital gain was duly examined by Ld. AO. The requisite queries were raised by Ld. AO which were duly replied by the assessee along with […]

Validity of Section 148 notice when escaped assessment is less than Rs.50 lacs

October 19, 2022 20820 Views 1 comment Print

Geeta Agarwal Wife Of Shri Navratan Agarwal Vs ITO (Rajasthan High Court) It is contended that as in the present case, the income, which is alleged to have escaped assessment, is far below Rs.50 lacs i.e., Rs.8 lacs, the bar under clause (a), sub-section (1) of Section 149 of the Act would come into play […]

Assessment order must mention bank details of bogus accommodation entries

October 18, 2022 1839 Views 0 comment Print

Boutique International Pvt Ltd Vs DCIT (Delhi High Court) Court finds that the information furnished to the Petitioner and the impugned order do not specify in which bank account or account number, the alleged amount have been received by the Petitioner. Though the impugned order states that the asset is represented by bogus accommodation entries in […]

Cash deposited during demonetization – HC allows reassessment

October 18, 2022 1719 Views 0 comment Print

Jain Cooperative Bank Limited Vs ACIT (Delhi High Court) As per the notice issued under Section 148A(b) the reassessment proceedings were initiated on the basis of suspicious transactions flagged by the FIU [Financial Intelligence Unit]. It is pertinent to mention that the petitioner is registered as a non-scheduled Urban Co­operative bank who ‘maintained current accounts […]

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