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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


Reassessment Invalid if Objection to reopening not disposed by Separate Speaking Order

December 18, 2020 3771 Views 0 comment Print

Admach Auto Limited Vs DCIT (ITAT Delhi) Disposal Of Objection To Reasons In Assessment Order Itself Without Separate Speaking Order Makes Entire Reassessment Invalid We have also gone through the objections dated 27.12.2016 filed by the assessee before the AO in which the assessee has specifically objected the initiation of proceedings u/s. 148 of the […]

Validity of Notice for reopening of assessment issued at old address of assessee

December 15, 2020 2943 Views 0 comment Print

Dart Infrabuild (P) Ltd. Vs ITO (ITAT Delhi) A conjointly reading of section 148 (1) of the Act with section 139 (4) of the Act and section 144 of the Act makes it abundantly clear that pursuant to the notice under section 148 of the Act, if an assessee files a belated return or letter […]

Addition on matters not related to reasons recorded for reassessment based on fishing enquiry not valid

December 14, 2020 3090 Views 0 comment Print

ITAT Mumbai: Anil K. Shah’s appeal against reassessment. Challenges various additions including expenses, borrowed funds, and alleged bogus purchases. Legal and evidential arguments presented.

Capital Loss cannot be treated as Bogus merely for unusual rise/ fall in price of Shares

December 11, 2020 1866 Views 0 comment Print

DCIT Vs Ganesh Plantation Ltd. (ITAT Ahmadabad) AO on one hand has recorded his finding with respect to the shares of certain companies that its face value stands at ₹10 but the assessee has purchased the same at a higher value. The basis of arriving at the conclusion that the assessee has purchased the shares […]

Section 50 applicable only on block of assets used for business and on which depreciation been claimed

December 5, 2020 4821 Views 0 comment Print

Delhi ITAT ruling: Assessment cannot be reopened merely on change of opinion. Long-term capital gain upheld. Depreciation disallowed. Full judgment.

Reopening on Borrowed Satisfaction Without Application of Mind Invalidates Reasons Recorded By AO

December 2, 2020 3576 Views 0 comment Print

Neel Builders Pvt. Ltd. Vs ITO (ITAT Delhi) A perusal of the reasons for reopening of the case for the impugned assessment year, copy of which is placed at paper book page No. 20-21 shows that the reopening was made on the basis of the report of the investigation wing and there is no independent […]

Claim Allowed in Original Assessment Cannot be Amenable to Provisions of Section 147/148

November 28, 2020 1200 Views 0 comment Print

The issue under consideration is whether the notice issued under section 147 for re-opening of assessment is justified in law? A claim which has been allowed in the original assessment proceedings after examination of the relevant details and facts cannot be amenable to provisions of Section 147/148 of the Act.

Enhancement by CIT(A) on an issue which were not part of reasons recorded for reopening the assessment are invalid

November 27, 2020 1698 Views 0 comment Print

Harendra Singh Vs ITO (ITAT Delhi) CIT(A) while deleting the sole foundational issue on which the re-assessment proceedings were initiated, cannot go further and examine an issue which was not even the subject matter of re-assessment proceedings Since the reopening was to verify the purchase transaction and since the said transaction never took place and, […]

Re-Opening of Assessment u/s 147 Merely Relying upon Investigation Report Not Justified in Law

November 27, 2020 1623 Views 0 comment Print

Eminent Computers Pvt. Ltd. Vs ITO (ITAT Delhi) The issue under consideration is whether the re-opening of assessment u/s 147 merely relying upon investigation report is justified in law? ITAT states that the return of income filed by the assessee has also been analyzed with reference to the information received from the Investigation Wing and […]

Reassessment based on Invalid Facts with no Application of Mind is Invalid

November 25, 2020 1740 Views 0 comment Print

M/s Aash Trading Company Pvt. Ltd. Vs ITO (ITAT Delhi) We find that AO in the reasons recorded has mentioned that Rs. 75 lacs on account of accommodation entry has been escaped, however, he had issued noticed u/s. 148 of the Act to the assesee. In response to the same, assessee filed the objection which […]

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