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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 189 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


ITAT Reduces Penalty as Tax Sought to Be Evaded Must Exclude TDS and Self-Assessment Tax

February 15, 2026 1584 Views 0 comment Print

The Tribunal upheld penalty for non-filing of return under Explanation 3 but ruled that computation must reduce TDS and self-assessment tax paid before notice. Penalty was reduced from Rs. 8.56 lakh to Rs. 85,992.

Reassessment Quashed – Wrong Sanction u/s 151 After 3 Years: ITAT Mumbai

February 14, 2026 696 Views 0 comment Print

ITAT held that approval by the Principal Commissioner was invalid where more than three years had elapsed from the assessment year. Since Section 151(ii) required sanction from PCCIT/CCIT, the reassessment was declared void.

Reassessment Quashed – Escaped Income Below ₹50 Lakh; Wrong Sanction Authority: ITAT Mumbai

February 14, 2026 627 Views 0 comment Print

ITAT held that under the amended law, reopening after three years is barred where alleged escaped income is under ₹50 lakh. The notice issued under Section 148 was declared invalid and reassessment proceedings were quashed.

Section 69 Addition on Alleged Cash in Property Deal Deleted – Third-Party Evidence Without Cross-Examination Insufficient

February 14, 2026 933 Views 0 comment Print

ITAT held that Excel sheets recovered from a third party cannot justify addition without direct evidence linking the assessee. In absence of corroboration and cross-examination, the cash investment addition was deleted.

Reopening U/s 147 quashed – Borrowed satisfaction mechanical approval U/s 151 invalid; sale of investments cannot be taxed U/s 68 – ITAT Kolkata

February 14, 2026 270 Views 0 comment Print

The Tribunal held that reopening based solely on investigation wing information without independent application of mind is invalid. Mechanical reasons cannot justify reassessment under Section 147.

Unsecured Loan Addition u/s 68 Deleted – Filatex Group Loans Held Genuine

February 14, 2026 390 Views 0 comment Print

ITAT Delhi upheld deletion of ₹60 lakh addition after finding that the assessee furnished confirmations, audited financials, bank statements, and Section 133(6) replies. In absence of direct evidence linking loans to accommodation entries, the addition under Section 68 was held unsustainable.

Assessment Quashed – Order by Non-Jurisdictional AO Void ab Initio: ITAT Chennai

February 14, 2026 438 Views 0 comment Print

The Tribunal held that statutory jurisdiction must be strictly followed in income-tax proceedings. In absence of proof of transfer to the assessing ward, the assessment was declared invalid and set aside.

Foreign HSBC Account Addition Deleted – BUP ID & Base Note Insufficient: ITAT Mumbai

February 14, 2026 597 Views 0 comment Print

The Tribunal held that failure to provide opportunity to cross-examine foreign information sources amounted to violation of natural justice. Additions based on unverified documents were therefore invalid.

Excess stock addition restricted – Survey working flawed; only disclosed difference taxable – ITAT Bangalore

February 14, 2026 342 Views 0 comment Print

The Tribunal ruled that incorrect computation of opening and closing stock during survey cannot justify full addition. Only the reconciled excess stock amount already offered to tax was sustained.

Reassessment Quashed – Invalid Sanction u/s 151(ii) by PCIT After 3 Years: ITAT Chennai

February 14, 2026 411 Views 0 comment Print

Where more than three years had elapsed, approval from the higher specified authority was compulsory before issuing notice. Failure to obtain such approval vitiated the reassessment proceedings.

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