#Section 148
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Delivery of notice u/s 148 at correct address of assessee is foundation for initiation of reassessment proceedings – ITAT

Failure of A.O. to dispose objections raised render re-assessment invalid

Photocopy of a document is acceptable evidence in income tax assessment proceedings

Reopen proceedings not valid in absence of any tangible material to substantiate escaped income

S. 147 Objections of assessee cannot be disposed off on an Imaginary Ground

Time barred assessment cannot be reopened for non satisfaction of conditions for reopening

Re-assessment proceedings cannot be initiated u/s 147 just because of change in opinion

An issue of jurisdiction can be raised at any time even in appeal or execution

Reopening is invalid when there is no direct nexus between material gathered & formation of belief of income escaping assessment

A collective understanding of Assessment Procedures

Reopening of completed assessments not justified in the event of true & full disclosure by assessee

Reassessment on the basis of change of opinion is forbidden by law

Reopening despite submission of all facts in relation to deduction claimed by assessee during original assessment is impermissible

Mere error would not confer jurisdiction to exercise revisional power U/s. 263
Explore the latest Section 148 updates on TaxGuru, including relevant Income-tax Act provisions, rules, notifications, circulars, judicial decisions and compliance guidance. The coverage highlights important tax positions, procedural requirements, assessments, deductions, penalties and litigation developments to help taxpayers and professionals understand the practical implications of changes in income-tax law.
