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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 513 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 63 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 51 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 33 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 63 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 63 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 5964 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


Twist in the Tale – Old Section 148 vs. New section 148A Controversy

September 5, 2021 35928 Views 6 comments Print

The deferment of application of old provisions of section 148 was done by the CBDT, Ministry of Finance by way of conditional legislation in the peculiar circumstances which arose during the pandemic and lock down. Hence, there being no full delegation of powers in the scenario, the Central Government cannot be said to have encroached upon turf of Parliament.

Limitation period for revisional proceeding in case of both Assessment & Reassessment

September 5, 2021 1788 Views 0 comment Print

CIT Vs Indian Overseas Bank (Madras High Court) The question as to whether the date, on which the order under Section 147 of the Act was passed should be reckoned as the starting point of limitation, considering the facts and circumstances of the case, has been dealt with by several decisions of the Hon’ble Supreme […]

Interim Protection against Section 148 Notice by MP High Court

September 4, 2021 1872 Views 0 comment Print

Jagadish Kumar Basantani Vs ITO Bhopal and Others (Madhya Pradesh High Court) Regard being had to the similitude of the questions involved, on the joint request of the parties, the matter is being heard on the question of admission and interim relief. Learned counsel for the petitioner submits that the petitioner has challenged the Constitutionality […]

Reassessment was erroneous in absence of prima facie finding by CIT

September 4, 2021 1350 Views 0 comment Print

CIT to at least record a prima facie finding that certain amount claimed by assessee as deduction in its computation of income de facto related to earning of dividend income. Thus, it was held that in the absence of any such prima facie finding, the reassessment was erroneous and no addition could be made under section 14A.

Latest Development in Section 148 Notices Issued After 31st March 2021

September 3, 2021 19431 Views 2 comments Print

The Finance Act, 2021 introduced a new set of reassessment proceedings from 01.04.21.The Central Board of Direct Taxes (C.B.D.T)  by way of various notifications had extended the time limit of issuing the notice U/s 148 of the Act up to  30th June, 2021. The Income tax department has issued many Section 148 notices for several […]

HC upheld validity of section 148 notices issued between 01.04.2021 to 30.06.2021 without following section 148A procedure

September 2, 2021 28281 Views 0 comment Print

Palak Khatuja Vs Union Of India (Chhattisgarh High Court) 1. The time for issuance of notice under Section 148, the end date was initially extended uptill on 30th day of April 2021 and subsequently again by notification dated 27th April, 2021 the time limit of 30th day of April 2021 was further extended up till […]

Reassessment restrained in 79 cases for not following section 148A procedure

September 2, 2021 3912 Views 1 comment Print

Revenue authorities were restrained from continuing with reassessment till further orders with respect to notices issued on or after 1-4-2021 without following the procedure prescribed under section 148A in 79 cases.

Reopening of assessment valid after Inquiry suggests the Assessee is beneficiary of Accommodation Entry

September 1, 2021 804 Views 0 comment Print

Gujarat High Court observed that it cannot be said that there is no reason to believe that the income chargeable to tax has escaped assessment. The exercise of reopening has only been made after due inquiries and recording of statements of concerned persons and notice has only been issued after finding prima facie material.

Reassessment notice invalid if AO not applied his mind & not supplied reasons

August 28, 2021 5181 Views 0 comment Print

R N Khemka Enterprises (P) Ltd. Vs ITO (ITAT Delhi) Co-ordinate Benches of the Tribunal are taking the consistent view that when there is non-application of mind by the AO to the report of the Investigation Wing, such reassessment proceedings are not in accordance with law and such reopening proceedings have been quashed. Since, in […]

Orissa HC stays section 148 notice issued in violation of section 148A

August 28, 2021 2028 Views 1 comment Print

Charana Panda (HUF) Vs ITO (Orissa High Court) 1. The Petitioner contends that there is violation of Section 148-A of the Income Tax Act, 1961 (‘Act’) and also that the proceedings are time barred. The competency of the officer who issued notice under Section 148 of the Act is also questioned. 2. Issue notice. 3. […]

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