#Section 148
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No new material besides full and true disclosure, reassessment u/s 148 is not justified

Reopening of Assessment u/s 147 cannot be allowed if there is any subsequent change in Law

Re-assessment proceedings concluded us/ 147 are invalid if notice u/s 143(2) is not issued

S. 147 Reopening based on material placed before DRP considering the same as new material

Reasons for initiating assessment u/s 147 should be recorded prior to issuance of notice u/s 148

Section 148 could not be invoked in absence of any Tangible Material

Reopening U/s 147 – `Incessant Trip to Litigation’

Reopening based on mere information received from Income Tax Investigation Wing not valid

Reassessment not justified if assessee had disclosed all the material facts and provided necessary documents during assessment proceedings

Section 147: Power of Review V/s Power to Re Assess

If AO not conducted proper inquiry, the obligation to do so is on CIT(A) & ITAT

Merely Approval without application of mind not sufficient and renders reopening void

Reopening on mere ground of Cash Deposit in Bank Account not Valid

Whenever order of Re-assessment is passed, Period of Limitation will start from the date of Re-assessment order and not from Original Assessment order
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.
