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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 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 2856 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 510 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 2472 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 148 Notice Based on Search Material Held Without Jurisdiction: Bombay HC

Income Tax : Bombay HC quashed Section 148 notices, holding that search-based material required proceedings under Sections 153A/153C, not Secti...

July 8, 2026 39 Views 0 comment Print

Section 147 Reopening Invalid Where Section 153C Procedure Applies: Karnataka HC

Income Tax : Karnataka HC held Section 147 reopening invalid where seized material from a third-party search required proceedings under Section...

July 8, 2026 36 Views 0 comment Print

Section 147 Reopening Invalid Where Section 153C Applies: SC

Income Tax : SC dismissed the SLP, leaving intact the HC ruling that Section 147 reopening was invalid where Section 153C procedure applied....

July 8, 2026 21 Views 0 comment Print

Section 148 Reopening on Stale Search Material Invalid: ITAT Kolkata

Income Tax : ITAT Kolkata upheld quashing of Section 148 reassessment, holding reopening on stale search material amounted to change of opinion...

July 8, 2026 39 Views 0 comment Print

Reassessment & Penalty Orders Against Deceased Person Are Nullity: Gujarat HC

Income Tax : Gujarat HC quashed reassessment and penalty orders issued against a deceased person, holding proceedings concluded against a dead ...

July 8, 2026 57 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


Reassessment merely based on Investigation Wing information is invalid

June 18, 2022 2004 Views 0 comment Print

Uma Strips Ltd. Vs DCIT (ITAT Delhi) In this case ITAT find that there is no live link presented by the AO between the material available with him i.e. the report of the investigation and to reason to belief that the assessee has tried to evade the assessment for the particular year in question. Simply […]

HC quashes section 148 Notice as Dept failed to give Minimum Time to Respond

June 18, 2022 3222 Views 0 comment Print

Shri Sai Co-Operative Thrift and Credit Society Ltd. Vs ITO (Delhi High Court) In the present case, though the petitioner responded to the show cause notice, yet it could not provide all the relevant details and documents, as the time period of three days to respond to the show cause notice was inadequate. Consequently, this […]

Madras HC directs dept to follow SC Judgment in UOI Vs. Ashish Agarwal

June 18, 2022 3141 Views 0 comment Print

Giant Construction Company Vs DCIT (Madras High Court) The petitioner assails the communication dated 21.04.2022 by which the objections raised by the petitioner to the reopening of the assessment were rejected. The petitioner asserts that the impugned communication is in contravention of the amended Section 148-A of the Income Tax Act, 1961. Upon the insertion […]

Non-jurisdictional AO cannot issue Section 148 notice to Appellant

June 16, 2022 2733 Views 0 comment Print

Louis Dreyfus Company Asia Pte. Ltd Vs CIT (International Taxation) (Delhi High Court) Learned counsel for the petitioner submits that since the impugned notice dated 30th March, 2019 has been issued under Section 148 of the Act by respondent no.3 based in Mumbai, who is a non-jurisdictional Assessing Officer, he is not entitled to exercise […]

HC direct AO to pass speaking order after considering submission of appellant

June 16, 2022 822 Views 0 comment Print

SL Lumax Ltd. Vs DCIT (Madras High Court) Without expressing any opinion on the merits of the case, HC is inclined to set aside the orders impugned herein as well as in the writ petition and are accordingly, set aside. Consequently, the matter is remanded to the assessing officer to decide the decision for reopening […]

Section 148 notice- HC directs dept to follow SC Judgment

June 16, 2022 2748 Views 0 comment Print

Raghav Trading Corp Vs ITO (Rajasthan High Court) When this case came up for hearing today, learned counsel for the parties jointly submitted that the issue raised in this petition would be covered by order dated 04.05.2022 passed by the Hon’ble Supreme Court in the case of Union of India & Others Vs. Ashish Agarwal […]

SC judgment not applies to Section 148 notice for AY 2013-14 to 2015-16

June 15, 2022 14901 Views 0 comment Print

Ajay Bhandari Vs Union of India (Allahabad High Court) Reassessment — Reopening of assessment — Reopening notice issued under unammended provisions — Reliefs sought in petition is to quash impugned notice u/s 148 — Held, as per Clauses 6.2 and 7.1 of Board’s Circular dated 11.05.2022, if a case does not fall under Clause (b) […]

Non-filing of return vis-à-vis cash deposit found in AIR, notice u/s 148 sustainable

June 13, 2022 2154 Views 0 comment Print

Sanjaykumar Gangaram Patel Vs ITO (ITAT Ahmedabad) Return not filed, however, cash deposit was found in AIR. Accordingly, AO issued notice u/s 148. Addition on cash deposited in bank account, opened with the assessee’s wife, is sustainable. Facts- The assessee is an individual. For AY 2006-2007, assessee has not filed a ROI. Annual Information Return […]

Draft of Reply to Section 148A(b) Notice considering SC Order

June 10, 2022 90615 Views 4 comments Print

Craft a strong response to Section 148A(b) Notice under the Income Tax Act, 1961. Leverage the Supreme Court order in Union of India vs. Ashish Agarwal dated 04-05-2022 to challenge and defend against the notice.

Section 148 Notice: Format of Reply on Letter Issued by AO Pursuant to SC Order

June 7, 2022 78204 Views 0 comment Print

Honorable Apex Court, in it’s judgment, in Para 10(iv) says as under: All defenses which may be available to the assesses including those available under section 149 of the IT Act and all rights and contentions which may be available to the concerned assessee and Revenue under the Finance Act, 2021 and in law shall continue to be available.

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