#Section 148
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No formation of opinion by AO if no scrutiny assessment made earlier

Fore initiation of Reassessment AO need not conduct inquiry & nor required to verify information, only nexus between Information & Belief required

Reassessment to disallow claim allowed earlier by change of opinion not permissible

Reassessment for thorough verification of manufacturing activity of Assessee not justified

Validity of Reopening based on retrospective amendment?

Initiation of Reassessment based on change of opinion not valid

If there is no failure on the part of assessee to disclose income, there was no escapement of income

Reassessment not valid if reasons recorded by AO were not sufficient ‘reasons to believe’

Order passed without dealing with objections filed by the Assessee is not valid

Reopening valid for Failure to disclose all material facts necessary for assessment

Reassessment to disallow Directors fees not valid if rationale already been explained during Assessment

Reassessment invalid on failure of AO to take note of information furnished during assessment

Transaction once accepted as genuine in assessment can’t be raised in reassessment proceedings

Reassessment – Deduction U/s 80-IC on manufacturing of PET bottles?
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.
