#Section 148
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For invoking reassessment proceedings, reasons has to be recorded & not conclusions

Section 153C Assessment of income of a person other than the person in whose case search has been initiated

S. 148 Approval for issue of notice for re-assessment

Reopening on ground of oversight, inadvertence or mistake is invalid

If Assessee is taxed under ‘MAT’ to ‘MAT’ – No Escapement, No Reopening

SC Nullifies Bombay HC Verdict on full & true disclosure of material facts

AO must intimate Assessee that reassessment proceedings been initiated with due approval

S. 148 Reopening based on re-appreciation of same material on record not valid

In case of disclosure of material facts of during original assessment proceeding, AO cannot issue re-assessment notice u/s 148 of the Act to find nature of same

AO can issue notice u/s 148 despite non expiry of time limit for issuing notice u/s 143(2)

Sanction for reassessment by JC in a mechanical manner is invalid

A.O Cannot act as a reviewing authorithy u/s 147 of Income Tax Act,1961

Since assessment made u/s 143(3), no notice can be issued without satisfaction of CCIT/CIT – S. 151(1)

Reopening of assessment Beyond a period of 4 years without Approval of Joint Commissioner not valid
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.
