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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 2862 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 66 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


Re-opening of concluded assessment not valid if no failure on the part of petitioner to disclose fully & truly all material facts

October 5, 2020 1377 Views 0 comment Print

State Bank of India Vs. Vineet Agrawal (Bombay High Court) we are of the considered opinion that no reasonable view can be taken that there was failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment for the assessment year 1990-91. If that be so then […]

Reopening not justified when all aspects were examined in original assessment proceedings

October 2, 2020 876 Views 0 comment Print

Nishit Fincap Pvt Ltd. Vs ITO (ITAT Delhi) Query No. 7 is in relation to share capital and share application money received. This means that specific query was raised in respect of share application money and vide reply dated 16.11.2009, the assessee furnished all details as required by the Assessing Officer. Pursuant to the reply […]

Issue examined under original assessment proceeding cannot be reexamined

October 1, 2020 894 Views 0 comment Print

DCIT Vs Manav Realty (ITAT Pune) It is evident from the reasons recorded by the AO that the initiation of reassessment proceedings was premised on the fact that the commencement took place at a date in variance with the one stated by the assessee in the original assessment proceedings. The ld. CIT(A) has aptly recorded […]

Reopening of Assessment not allowed to Form Change of Opinion

September 25, 2020 1263 Views 0 comment Print

The issue under consideration is whether the reassessment proceeding u/s 147 initiated to form change of opinion which clearly amount to reviewing the original order of assessment is justified in law?

Reopening without bringing out any fresh material on record is unjustified

September 24, 2020 1416 Views 0 comment Print

ACIT Vs Shiv Offset India Pvt. Ltd. (ITAT Indore) In the instant case the Ld. A.O had passed the original assessment taking into consideration of all the documents and facts of the case and again he had reopened the case without bringing out any fresh material on record and thus there was a mere change […]

Reassessment not valid if No notice under section 143(2) issued to assessee

September 23, 2020 2610 Views 0 comment Print

Supertron Electronics Pvt. Ltd Vs DCIT (ITAT Kolkata) The admitted fact is that no notice u/s 143(2) of the Act was issued to the assessee for both the assessment years. Only a notice u/s 148 and Section 143(2)(1) of the Act was issued. Under these circumstances we have to hold that the assessment orders for […]

AO cannot reopen a case to re-examine issue examined during original assessment

September 22, 2020 2268 Views 0 comment Print

DCIT Vs Indian Metals & Ferro Alloys Ltd (ITAT Cuttack) In this case there is nothing to suggest that all the primary facts were not disclosed by the assessee at the time of original assessment completed u/s 143(3) of the Act nor any failure on the part of the assessee to disclose fully and truly […]

Assessment cannot be reopened u/s 147 Based on Material Assessed by AO in Original Assessment

September 11, 2020 1179 Views 0 comment Print

The issue under consideration is whether reopen assessment u/s 147 based on the same material which is examined by AO in original assessment is justified in law?

Reopening of Assessment for mere Difference in Valuation Report Not Justified

September 7, 2020 3168 Views 0 comment Print

The issue under consideration is whether the issue of notice u/s 147 for re-opening of assessment on the basis of difference in valuation report is justified in law?

Reopening to assess Income under different head due to change of opinion is invalid

August 31, 2020 1434 Views 0 comment Print

Reopening of assessment to assess the remuneration under the head ‘income from salary’ instead of ‘income from other sources’ constitutes difference of opinion and the AO is not permitted to reopen the assessment on difference of opinion

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