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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


Section 55: AO cannot reject valuation report without proving lesser valuation

June 7, 2020 6306 Views 0 comment Print

DCIT Vs Ajanta Tubes Ltd. (ITAT Delhi) The issue under consideration is whether the A.O. is correct in rejecting the valuation report obtained by the assessee? In the present case, assessee had sold its land and building. Assessee had taken the cost of acquisition for land as per valuation report as at 1-4-1981 as against […]

Reassessment merely on Investigation officer report is unsustainable

June 7, 2020 1764 Views 0 comment Print

Ashapura Minichem Limited Vs DCIT (ITAT Mumbai) The issue under consideration is whether the re-opening of assessment u/s 147 is justified in law? The assessee before us is a listed public limited company engaged in the business of mining bauxite and selling the same in domestic as well as international market. In the present case […]

Dealing with reassessment under Income Tax Act, 1961

June 4, 2020 9177 Views 0 comment Print

As per section 2(8) of the Income Tax Act, 1961, the term assessment includes re-assessment. Meaning of income escaping assessment: As per the provisions contained in section 147 of the Income Tax Act, 1961, if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, […]

Mere bald assertions by AO in reasons for reopening would confer valid jurisdiction to AO to Reopen?

June 3, 2020 1830 Views 0 comment Print

Each aspect of Section 147 has been a subject matter of careful scrutiny by the court of law. One such main issue is with respect to the validity of the assumption of jurisdiction by the AO to reopen the assessment beyond four years, merely by making a Bald Assertion in the reasons as to the failure of the Assessee to disclose fully and truly all the material facts. The author has made an analysis veracity of such practice with the help of available judicial pronouncements

MSBTE is ‘State’ under Indian Constitution & Exempt from Income Tax

June 3, 2020 2499 Views 0 comment Print

The issue under consideration is whether CIT(A) is correct in holding that the appellant is not a state under Article 289 of the Constitution of India and therefore, liable to tax under the Income Tax Act?

Assessee can claim Section 54F deduction during Section 147 Proceedings

June 2, 2020 5157 Views 0 comment Print

Whether AO is correct in rejecting the claim of assessee regarding the deduction u/s 54F, which was made first time during Reassessment Proceedings?

No section 147 notice based on material already presented during section 143(3) assessment

May 30, 2020 2199 Views 0 comment Print

The issue under consideration is whether A.O. is correct in issuing Notice under section 147 for re-opening of assessment irrespective of the fact that the material on which he relied is already present in front of him at the time of assessment u/s 143(3)?

No reassessment after 4 years in case there was no disclosure failure on the part of assessee

May 29, 2020 3786 Views 0 comment Print

AO was not justified in reopening of assessment after four years as on an independent application of mind and on thorough consideration of material aspects and legal position,there was no failure on the part of assessee.

AO cannot issue fresh notice when proceedings on a previous section 148 notice still pending

May 29, 2020 4023 Views 0 comment Print

DCIT Vs Coal India Ltd (ITAT Kolkata) Section 148 of the Act does not authorize the AO to issue fresh notice when proceedings on a previous notice u/s. 148 of the Act are still pending and have not been finally disposed of. Similar view was taken by the Hon’ble Allahabad High Court in Commercial Art […]

Section 68: Sales declared as Income in books cannot be treated as cash credit

May 29, 2020 6735 Views 0 comment Print

ITAT states that the assessee has disclosed the sale of shares in its books of account. Once the sale is declared as income by the assessee, the question of treating the same amount as a cash credit u/s 68 of the Act results in double addition. Thus, the addition is also bad on merits. Hence, the appeal of the assessee is allowed.

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