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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 333 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 14058 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 2820 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 498 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 1050 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


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

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 252 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 579 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 285 Views 0 comment Print

1439-day delay in Filing Appeal Condoned & Matter Remanded for Fresh Assessment: ITAT Kolkata

Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...

July 5, 2026 279 Views 0 comment Print

Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...

July 5, 2026 225 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 58935 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 6018 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 5985 Views 0 comment Print


Reassessment Invalid as Mere Change of Opinion Is Not Reason to Believe: Karnataka HC

May 7, 2026 417 Views 0 comment Print

The Karnataka High Court Full Bench ruled that reassessment under Section 147 cannot be initiated merely because the Assessing Officer changes his opinion on the same material. The Court reaffirmed that reassessment requires tangible material showing escapement of income.

ITAT Jaipur Deletes Additions as Clandestine Sales Allegation Failed Before CESTAT

May 7, 2026 399 Views 0 comment Print

ITAT Jaipur held that additions for unexplained sales and investment could not survive once the CESTAT rejected allegations of clandestine removal of goods. The Tribunal deleted additions made under Sections 69A and 69C.

Interest on Compulsory Acquisition of Agricultural Land Still Exempt – ITAT Pune Deletes Tax & Penalty Together

May 7, 2026 876 Views 0 comment Print

The ITAT observed that interest awarded under Section 28 of the Land Acquisition Act differs from ordinary interest under Section 34 and forms part of enhanced compensation. Therefore, taxation provisions relating to interest income were held inapplicable.

ITAT Restricts Bogus Purchase Addition Due to Lack of Independent Enquiry by AO

May 7, 2026 609 Views 0 comment Print

The Tribunal held that full disallowance of purchases was not justified where corresponding sales and quantitative stock records were accepted. ITAT sustained only estimated disallowance at 12.5% of disputed purchases.

Reassessment Invalid Because Approval Contained Only ‘Yes, I Am Satisfied’: ITAT Rajkot

May 7, 2026 438 Views 0 comment Print

ITAT Rajkot held that reassessment proceedings were invalid because the approving authority merely stated Yes, I am satisfied without independent application of mind. The Tribunal treated Section 151 approval as a mandatory procedural safeguard.

SC Declines Reassessment Revival as Income & Transactions Were Fully Disclosed in ITR

May 7, 2026 504 Views 0 comment Print

The Supreme Court refused to interfere with the Gujarat High Court ruling quashing reassessment proceedings where the assessee had disclosed all transactions in audited accounts and income tax returns. The Court left the question of law open.

No “reason to believe” without new material – Mumbai ITAT quashes reopening based on mere reappraisal of old records

May 7, 2026 162 Views 0 comment Print

Mumbai ITAT held that reassessment under Section 147 cannot be initiated merely by reviewing records already examined during original scrutiny. Absence of fresh tangible material made the reopening legally invalid.

ITAT Pulls Up AO for Ignoring Evidence, Sends ₹31.61 Lakh Addition Back for Verification

May 7, 2026 321 Views 0 comment Print

The Mumbai ITAT held that the AO and CIT(A) failed to properly verify bank statements, credit card records, and company ledger accounts before making the addition under Section 68. The matter was restored for fresh examination and reconciliation of records.

Opening Loan Balances Not Taxable Again u/s 68: Mumbai ITAT Sends Addition Back for Verification

May 7, 2026 183 Views 0 comment Print

The ITAT held that old unsecured loan balances carried forward from earlier years cannot automatically be treated as unexplained cash credits in a subsequent year.

Only One Surviving Day Left: Mumbai ITAT Quashes Time-Barred Reassessment Notices After Rajeev Bansal Ruling

May 7, 2026 435 Views 0 comment Print

The ITAT held that reassessment notices issued on 25.07.2022 were time-barred since the Revenue had only one surviving day left under the Supreme Court’s Rajeev Bansal limitation formula.

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