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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 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


Reopening by change of opinion on facts already examined is not valid

May 15, 2022 1446 Views 0 comment Print

Re-opening proposed is purely based on change of opinion and entire issue which is subject matter of reasons recorded has been raised during assessment proceedings

Allowing mere 8 hours to reply to SCN is neither reasonable nor effective

May 15, 2022 2757 Views 0 comment Print

Court is of the view that time of eight hours to file reply to the show cause notice was neither reasonable nor effective, as within this short time, the Petitioner could not have supplied relevant information and documents to substantiate his case.

An Appeal to Regularize Income Tax Reassessment Proceedings

May 14, 2022 6069 Views 0 comment Print

Unlock the intricacies of Income Tax reassessment proceedings under Section 147 of the Income Tax Act, 1961. Explore key amendments through the Finance Act, 2021, including the introduction of Section 148A. Delve into the implications of notices, time limits, and the recent legal developments. Stay informed on the changing landscape of tax reassessment.

Reassessment Based on wrong and incorrect facts is bad in law

May 14, 2022 3816 Views 0 comment Print

Keshav Saran Vs ACIT (ITAT Delhi) In the present case, the assessee has actually filed the return of income and the Assessing Officer in the satisfaction note noted that the assessee has not filed return of income. Thus, we safely presume that the Assessing Officer has initiated reassessment proceedings by mentioning wrong and incorrect facts […]

Reopening on wrong assumption of facts by AO cannot be sustained

May 14, 2022 1227 Views 0 comment Print

ITAT held that that the A.O. has ventured on a wrong assumption of facts though the agreement was available on hand with the A.O. in the original assessment proceedings. Considering the facts and circumstances are of the opinion that the reopening on the wrong assumption of facts by the assessing officer cannot be sustained.

HC quashes Reassessment order passed Without issuing Section 148 Notice

May 14, 2022 789 Views 0 comment Print

Govardhan Commodities Pvt. Ltd. Vs. ACIT/DCIT (Calcutta High Court) In this matter, petitioner has challenged the impugned assessment order dated 19th March, 2022 under Section 147 read with Section 144 of the Income Tax Act, 1961 relating to the assessment year 2014-15 being Annexure P-5 to the writ petition, on the ground that the same […]

Issue of Section 148A notice mandatory before issuing any notice U/s. 148

May 14, 2022 1137 Views 0 comment Print

Dinesh Agarwal Vs ACIT (Calcutta High Court) Considering these facts, HC was of the considered view that this case clearly falls under the amended Act relating to proceedings under section 147 of the Act under which issuance of notice under section 148A of the Act is mandatory before issuing any notice under section 148 of […]

Fresh Controversies In Reassessment- Misfortune or Misinterpretation

May 12, 2022 3933 Views 0 comment Print

Uncover the controversy surrounding reassessment notices under section 148 of the Income Tax Act. Explore the Supreme Court judgment, CBDTs interpretation, and the potential impact on past assessment years. Delve into the misfortune or misinterpretation in this legal landscape.

Curious Case of Missing First Proviso to Section 149 & Miscounting of 3 Years, in CBDT Instruction on SC Judgment

May 12, 2022 14919 Views 6 comments Print

Unravel the intricacies of CBDT Instruction No. 01/2022 on SC Judgment Union of India vs Ashish Agarwal. Dive into the curious case of missing provisos in Section 149 and a miscounting of 3 years, exposing potential flaws and implications in reassessment notices. Stay informed on the evolving landscape of tax regulations.

Section 148 Notices: Steps to follow in cases impacted by SC decisions

May 12, 2022 7563 Views 0 comment Print

ITBA Step–by–Step Document No. 1 w.r.t. CBDT Instruction No. 1 of 2022Dated 12.05.2022 Steps to be followed in ITBA for the cases impacted by Hon’ble Supreme Court decision dated 04.05.2022 in the case of Union of India vs. Ashish Agarwal Dated 12.05.2022 NOTE: The AOs/ITBA users should refer to Instruction No. 1 of 2022 dated […]

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