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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 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 4587 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 75 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 36 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 72 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


In absence of issue of notice U/s. 143(2) assessment U/s. 143(3) r.w. section 147 was invalid and void ab initio

March 4, 2018 6501 Views 1 comment Print

Shri Ramesh Salecha HUF Vs. ITO (ITAT Mumbai) Revenue could not produce before us any evidence to show that notice under sections 143(2) has been issued or served to the assessee the re-assessment made under sections 143(3) read with section 147 is void ab-initio in view of the above decisions of the Honorable Allahabad High Court in […]

Section 148 Notice in the name of non-existent firm was null and void

February 28, 2018 10428 Views 0 comment Print

AO issued notice under section 148 in the name of firm which had been converted into a private limited company. Assessee’s case was that re-assessment order passed by AO under section 143(3) read with section 147 was null and void. Held: Undisputedly, reassessment proceedings were initiated by AO on a non-existent firm and hence, reassessment order was null and void.

Re-Assessment Invalid if order sheet recording reason for reopening is unsigned

February 28, 2018 2385 Views 0 comment Print

Sri Pinnamaraju Venkatapathi Raju Visakhapatnam Vs JCIT (ITAT Visakhapatnam) In the instant case, on verification of the assessment record, it is noticed that the A.O. typed the reasons but not signed the order sheet, thus there are no reasons recorded for reopening of assessment as required u/s 148 of the Act. The A.O. neither complied […]

Unsigned reason cannot be treated as reasons recorded

February 28, 2018 2253 Views 0 comment Print

Where AO typed the reasons but not signed the order sheet, there were no reasons recorded for re-opening assessment as required under section 148, therefore, notice issued under section 148 was bad in law, consequently reassessment order was to be annulled.

Section 148 notice without proper sanction U/s. 151(1) is invalid

February 27, 2018 5460 Views 0 comment Print

The present petition under Article 226 of the Constitution of India has been filed assailing the notice dated 28.03.2017 issued under Section 148 of the Income Tax Act, 1961 (in short, the Act) and also the order dated 25.09.2017 whereby the objections preferred by the petitioner questioning the issuance of notice dated 28.03.2017 was rejected.

Notice U/s. 148 invalid if AO not issued notice U/s. 143(2)

February 21, 2018 8940 Views 0 comment Print

Pr. CIT Vs. Paramount Biotech Industries Ltd. (Delhi High Court) The proposal to reopen an assessment under section 147 of the Act is to be based on reasons to be recorded by the assessing officer. Such reasons have to be communicated to the assessee. However, merely because the assessee participates in the proceedings pursuant to […]

HC finds no merit in Challenge to Reassessment Notice issued to Robert Vadra’s Firm

February 20, 2018 2154 Views 0 comment Print

Delhi High Court has refuses to set aside re-assessment notice U/s. 147/148 issued by Income Tax Department to the partnership firm Sky Light Hospitality, in which Robert Vadra is a partner, in connection with the DLF- Sky Light Hospitality land deal.

Mere Issue of 2nd notice U/s. 148 does not constitute Change of Opinion; AO can examine genuineness of share premium U/s 68

February 9, 2018 1488 Views 0 comment Print

The assessee, a company stated to be engaged in Real Estate business, filed its return of income for Assessment Year 2008-09 on 30.09.2008 declaring loss of (-) Rs.6,84,051. The assessee filed a revised return on 14.10.2008 declaring loss of (-) Rs.5,23,751. The revised return was processed under Section 143(1) of the Income Tax Act

Sec 292B can’t be cure Non-application of mind in issue of Re-Assessment Notice

February 7, 2018 2040 Views 0 comment Print

Smt. Kalpana Shantilal Haria Vs. Assistant CIT (Bombay High Court) There can be no dispute with regard to the application of Section 292B of the Act to sustain a notice from being declared invalid merely on the ground of mistake in the notice. However, the issue here is not with regard to the mistake / […]

No reassessment merely for non reflection of ITR filed manually in IT system

February 7, 2018 3366 Views 0 comment Print

In ground No. 1 of the appeal, the assessee has challenged the initiation of proceedings u/s. 147 of the Act for deposition of cash of Rs. 1057000 in the saving bank account during the financial year 2006-07 based on AIR Information and not filing of return of income by the assessee.

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