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Section 148

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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 510 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 42 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 39 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 21 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 39 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 57 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


HC allow reopening in the case related to accommodation entries

August 27, 2021 2814 Views 0 comment Print

Geetaben Dineshchandra Gupta Vs ITO (Gujarat High Court) Geetaben Dinesh chandra Gupta (Petitioner) has filed the current petition challenging the notice dated March 23, 2019 which proposed the reopening of assessment of the Petitioner under Section 148 of the Income Tax Act, 1961 (the IT Act). The Petitioner contended that even after the petitioner disclosed […]

Reopening after enquiries valid if Assessee is beneficiary of accommodation entries

August 26, 2021 2733 Views 0 comment Print

Bharatkumar Kalubhai Ghadiya Vs ACIT (Gujarat High Court) In the case on hand also, the Assessing Officer has reason to believe that the petitioner is a beneficiary of accommodation entry and basis for formation of such belief is several inquiries and the investigation by the Investigation Wing, Ahmedabad and report thereof. The reasons for the […]

AO must establish a live-link between escapement of income vis-à-vis Fresh information

August 24, 2021 2436 Views 0 comment Print

ITO Vs Gujarat Storages P.Ltd. (ITAT Ahmedabad) As far as banking transactions are concerned, these details were available with the AO. This information was given in the audited accounts. Any transactions shown in the bank statement could never be construed per se as an escaped income. It is the AO who has to form his […]

HC stays section 148 notice issued after 31.03.2021 as per omitted provisions

August 18, 2021 1722 Views 0 comment Print

Vijay Kumar Devnani Vs ITO and Anr. (Madhya Pradesh High Court) Madhya Pradesh High Court Stays Section 148 notice issued after 31st March 2021 as per the section 148 provisions which were effective only till 31st March 2021. The petitioner has challenged the validity of the Notification No. 20/2021 dated 31.03.2021 and Notification No. 38/2021 […]

HC stays section 148 notice issued after 31st March, 2021

August 18, 2021 2457 Views 0 comment Print

Sai Kripa Farms Vs ITO (Madhya Pradesh High Court) In this judgements notice issued u/s 148 have been stayed by the Madhya Pradesh High Court for being issued after 31st March, 2021 as per the omitted provisions. The petitioner has challenged the validity of the Notification No. 20/2021 dated 31.03.2021 and Notification No. 38/2021 dated […]

Reopening for accommodation entry based on inquiries & Investigation report was valid: HC

August 18, 2021 3876 Views 0 comment Print

Sanjay Baulal Surana Vs ACIT (Gujarat High Court) 1. The function of the assessing authority at this stage is to administer the statute and what is required is a reason to believe and not to establish fact of escapement of income and therefore, looking to the scope of Section 147 as also sections 148 to […]

Section 148 Reassessment order passed in case of non-existent entity is void

August 16, 2021 5334 Views 1 comment Print

Case Name: Teleperformance Global Services Private Limited vs ACIT (Bombay High Court) Written Petition No 950 of 2020 Date of judgment/order: 09.04.2021 Related Assessment Year – 2012-13 Court: Bombay High Court The Hon’ble Bombay High Court has in case of writ petition filed by Teleperformance Global Services Private has held that assessment order passed against […]

Writ Petition Against section 148 Notices In Bombay High Court

August 16, 2021 9198 Views 0 comment Print

Mansi Ankit Bhalaria Vs Union of India And Ors. (Bombay High Court) A  NUMBER OF WRITS FILED IN BOMBAY HIGH COURT AGAINST NOTICES UNDER SECTION 148 AND VIRES OF TAXATION AND OTHER LAWS ACT 2020 ALSO CHALLENGED, STAY GRANTED According to petitioners, the extension of time limit granted under The Taxation and Other Laws (Relaxation […]

Delhi HC stays Section 148 Proceedings in 42 cases

August 14, 2021 5094 Views 0 comment Print

SG Corporation Joint Venture Vs ITO & Ors. (Delhi High Court) 1. The respondents are restrained from continuing with the reassessment proceedings, in any manner, pursuant to the impugned notices. 2. No adjournment shall be granted on the next date of hearing. FULL TEXT OF THE HIGH COURT ORDER /JUDGEMENT On 13th July, 2021, this […]

Reassessment after 4 year invalid if assessee disclosed all material facts during original assessment

August 13, 2021 1221 Views 0 comment Print

CIT Vs Mr. John Ettimootil Samuel (Madras High Court) 1. Sets aside reassessment framed u/s 147 after expiry of four years of assessment u/s 143(3), holding that the assessee had disclosed all material facts in the original assessment qua consideration and deemed consideration u/s 50C of the Act. 2. The Tribunal was fully justified in […]

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