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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 333 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 14058 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 2823 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 498 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 1053 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 2469 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


Unaccounted sales must be taxed on net profit basis, not on gross profit

Income Tax : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...

July 7, 2026 273 Views 0 comment Print

Section 56(2)(x) Applicability Depends on Agreement Date; Mistaken Tax Payment Refundable: ITAT Mumbai

Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...

July 6, 2026 657 Views 0 comment Print

APMC Commission Agent Not Taxable on Entire Sale Proceeds; Section 69A Issue Remanded: ITAT Bengaluru

Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...

July 6, 2026 291 Views 0 comment Print

1439-day delay in Filing Appeal Condoned & Matter Remanded for Fresh Assessment: ITAT Kolkata

Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...

July 5, 2026 285 Views 0 comment Print

Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...

July 5, 2026 228 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 5961 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 58938 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 6018 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 5985 Views 0 comment Print


Reopening Quashed: ITAT Slams Casual 148A Action Where ₹50L Threshold Not Met

April 25, 2026 3930 Views 0 comment Print

The Tribunal held reassessment invalid as the alleged escaped income did not exceed ₹50 lakh required for extended limitation. It ruled that invoking extended time under Section 149 without satisfying this condition is illegal.

Accommodation Entry Commission Restricted to 0.5% – Addition Reduced to Actual Involvement

April 25, 2026 729 Views 0 comment Print

The issue was estimation of commission income from alleged accommodation entries. The tribunal held that addition should be restricted to 0.5% on proven transactions, not inflated amounts.

Section 80GGC Deduction Denied – Bogus Political Donation Upheld on Human Probability Test

April 25, 2026 1017 Views 0 comment Print

The issue was whether donation to a political party qualified for deduction under Section 80GGC. The tribunal held the claim was not genuine and upheld disallowance due to lack of credibility.

On-Money Addition u/s 69 Deleted – Third-Party Excel Data & Statements Held Insufficient

April 24, 2026 738 Views 0 comment Print

ITAT Mumbai deleted Section 69 addition on alleged on-money, holding third-party statements and unverified pen drive data lack evidentiary value without corroboration or cross-examination, upholding natural justice.

Reassessment Quashed for Lack of Jurisdiction: AO Became Functus Officio After Section 127 Transfer

April 24, 2026 468 Views 0 comment Print

The issue was whether reassessment initiated by a non-jurisdictional AO is valid. The tribunal held that proceedings are void ab initio when jurisdiction had already been transferred under Section 127.

Reassessment Quashed – Invalid Sanction by PCIT Instead of PCCIT Beyond 3 Years

April 24, 2026 606 Views 0 comment Print

ITAT held that reassessment beyond three years requires approval from the higher authority, not PCIT. Since approval was wrongly obtained, the entire reassessment was quashed.

Additional Evidence Admitted Post Death – ₹7.79 Cr Addition Restored for Fresh Verification

April 24, 2026 276 Views 0 comment Print

ITAT allowed additional evidence filed by the legal heir and remanded the matter to the AO for verification. The key takeaway is that justice requires giving opportunity where evidence was earlier unavailable.

Credit Card Payments Explained – Addition u/s 69C Deleted in Absence of Unexplained Source

April 24, 2026 474 Views 0 comment Print

The Tribunal noted that the assessee provided affidavits, bank statements, and financials of contributors. The addition was deleted as the source stood satisfactorily explained.

CM-Based Addition Deleted – No Evidence Beyond Investigation Wing Information

April 24, 2026 456 Views 0 comment Print

The Tribunal found that the AO relied only on general information without corroborative material. The ruling emphasizes that suspicion cannot replace proof in tax proceedings.

Reassessment Time-Barred Despite TOLA SC Relaxation – Notice Held Void

April 24, 2026 456 Views 0 comment Print

The notice issued after the permissible window calculated under TOLA and judicial rulings was held void. The case highlights strict adherence to limitation timelines.

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