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Section 148

Latest Articles


Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...

May 13, 2026 405 Views 0 comment Print

Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 759 Views 0 comment Print

Reassessment Invalid as AO Failed to Issue 143(2) Notice After Belated Return

Income Tax : ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143...

April 2, 2026 1140 Views 0 comment Print

Delay in Recording Satisfaction Note Under Section 153C Can Invalidate Search Proceedings

Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...

March 11, 2026 1866 Views 0 comment Print

Updated Return After Reassessment Notice Comes With Higher Tax Cost Because Additional 10% Levy Proposed

Income Tax : The Finance Bill 2026 proposes allowing taxpayers to file an Updated Return even after receiving a reassessment notice under Secti...

March 6, 2026 2373 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 2286 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 4404 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 6882 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 7494 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 13347 Views 0 comment Print


Latest Judiciary


ITAT Indore Sets Aside Ex Parte CIT(A) Order as Notices Were Sent to Wrong Email Address

Income Tax : ITAT Indore held that appellate order violated principles of natural justice after finding that key hearing notices were sent to a...

May 22, 2026 105 Views 0 comment Print

Section 148 Notice Invalid as It Was Issued by JAO Instead of FAO: Rajasthan HC

Income Tax : Court ruled that reassessment notices under Section 148 must be issued through the faceless mechanism under Section 151A and the 2...

May 22, 2026 333 Views 0 comment Print

Madras HC Quashes Section 148 Notices as They Were Issued by Jurisdictional AO

Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...

May 22, 2026 780 Views 0 comment Print

Reassessment Notices Invalid as Faceless Procedure Was Not Followed: Madras HC

Income Tax : The Madras High Court held that reassessment notices required to be issued by the Faceless Assessing Officer are invalid if issued...

May 22, 2026 699 Views 0 comment Print

Jharkhand HC Upholds Reassessment Proceedings as Finance Act 2026 Inserted Section 147A Retrospectively

Income Tax : The Jharkhand High Court held that retrospective insertion of Section 147A removed the jurisdictional challenge against reassessme...

May 22, 2026 195 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 1026 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 5832 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 57513 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 5898 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 5910 Views 0 comment Print


Delhi HC Dismisses Reopening Based Solely on Audit Objection

February 20, 2026 669 Views 0 comment Print

elying on Supreme Court precedent, the Court upheld ITAT’s finding that reopening based on reappraisal of existing records is invalid. The Revenue’s appeal was dismissed.

ITAT Bangalore: Cost of Construction Cannot Be Fully Disallowed; Matter Remanded to AO for Fresh Verification & Valuation

February 20, 2026 615 Views 0 comment Print

The ITAT Bangalore held that the entire cost of construction claimed by the assessee while computing capital gains on sale of property could not be outrightly disallowed merely due to lack of complete supporting documents.

ITAT Bangalore Quashes Reopening Based on Wrong Bogus LTCG Assumption; Deletes Double Addition U/s 68

February 20, 2026 381 Views 0 comment Print

The ITAT Bangalore held that reopening of assessment was invalid as it was based on an incorrect assumption that the assessee had claimed bogus long-term capital gains (LTCG) from penny stock transactions.

ITAT Quashes ₹11.23 Cr Reassessment as Section 148 Notice Held Time-Barred

February 20, 2026 711 Views 0 comment Print

The Tribunal held that the reassessment notice issued after the extended limitation period was invalid under Section 149. As a result, the entire reassessment based on alleged accommodation entries was quashed as void ab initio.

Reassessment After 31-03-2024 Time-Barred; First Proviso to Sec. 149(1) Prevails Over 148A – Proceedings Quashed by ITAT Bangalore

February 20, 2026 948 Views 0 comment Print

ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.

ITAT Deletes Section 68 Addition as AO Relied Solely on Generalized Penny Stock Report

February 20, 2026 5082 Views 0 comment Print

The Tribunal held that mere reliance on an Investigation Wing report without linking the assessee to price manipulation cannot justify treating LTCG as bogus. Documentary evidence and banking transactions supported genuineness.

Reassessment Quashed as Year of Search Cannot Be Reopened Under Section 148

February 19, 2026 699 Views 0 comment Print

The Tribunal held that reassessment under Sections 147/148 is invalid when the assessment year is the year of search. Such cases must proceed under normal assessment provisions.

ITAT Recalls Order Due to Non-Consideration of Conditional Withdrawal of Grounds

February 19, 2026 450 Views 0 comment Print

The Tribunal recalled its earlier order after finding that the assessee’s conditional withdrawal of reopening grounds was not properly considered. The matter was directed for fresh adjudication to address legal and factual issues.

Bombay HC Quashes Reassessment as Section 148 Notice Issued by Wrong Authority

February 19, 2026 1131 Views 0 comment Print

The Court held that issuance of notice under Section 148 by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer is a jurisdictional defect. All consequential reassessment proceedings were set aside.

Mere Third-Party Excel Sheet Insufficient for Section 69 Addition: ITAT Chandigarh

February 19, 2026 5379 Views 0 comment Print

The alleged unexplained investment was based only on third-party statements and seized digital data. In absence of receipts, confirmations, or admission by the assessee, the addition of ₹50 lakh was deleted.

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