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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 258 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 615 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 285 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 58935 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


Interest on deposits linked to business setup was capital receipt and not taxable as ‘Income From Other Sources’

April 20, 2026 795 Views 0 comment Print

Interest earned on funds kept in bank during business setup, when those funds were directly linked to the project, was a capital receipt and not taxable as “income from other sources

HC Quashes 148A(d) & Ex-Parte Assessment; Matter Restored to 148A(b) Stage for Fresh Reply

April 20, 2026 375 Views 0 comment Print

Karnataka High Court quashes Sec 148A(d), Sec 148 notice and ex-parte assessment due to non-receipt of Sec 148A(b) notice; remands for fresh reply, keeps all issues open.

Bombay Quashed Section 148 Notice Due to Issuance by Wrong Authority

April 18, 2026 3264 Views 0 comment Print

The issue was whether a reassessment notice issued by a jurisdictional officer instead of a faceless officer is valid. The Court held it to be a fatal defect and quashed the notice.

JDA May Trigger Transfer- But No Double Taxation Allowed: Karnataka HC Relief

April 18, 2026 642 Views 0 comment Print

The issue involved taxing capital gains from a development agreement in multiple years. The court held the same income cannot be taxed twice and set aside the addition subject to verification.

Bogus Purchases: Only Profit Element Taxable – ITAT Upholds 12.5% Estimation

April 18, 2026 516 Views 0 comment Print

ITAT Mumbai upheld 12.5% addition on alleged bogus purchases, ruling that only profit element can be taxed since sales were accepted; full disallowance or 25% addition was held excessive and unjustified.

Reopening on Change of Opinion Invalid: ITAT Quashes Entire Assessment

April 18, 2026 321 Views 0 comment Print

The Tribunal quashed reassessment proceedings as they were based on a mere change of opinion without any fresh tangible material. It held that re-examining already scrutinized facts does not justify reopening under section 147.

Reassessment Time-Barred Despite TOLA & Ashish Agarwal: ITAT Upholds Quashing

April 18, 2026 375 Views 0 comment Print

Applying the computation method laid down in Rajeev Bansal, the Tribunal found the notice was issued late. The ruling confirms that delayed notices are void even with extended timelines.

Reassessment for AY 2015-16 Time-Barred – ITAT Quashes Entire Penny Stock Addition

April 18, 2026 522 Views 0 comment Print

ITAT Mumbai quashed reassessment for AY 2015–16 as time-barred under amended Section 149, since escaped income was below ₹50 lakh; entire penny stock addition u/s 68 was held void without examining merits.

Penalty U/s 272A(1)(d) Deleted: Reasonable Cause Subsequent Compliance Accepted

April 18, 2026 717 Views 0 comment Print

The Tribunal held that penalty under Section 272A(1)(d) cannot be imposed when notices were sent to an inaccessible hacked email. It accepted that delayed compliance had a reasonable cause. The ruling emphasizes fairness in penalty proceedings.

CIT(A) Cannot Enhance on New Issue; JDA Additions & U/s 2(22)(e) Deletions Upheld

April 18, 2026 525 Views 0 comment Print

ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling clarifies that such action exceeds jurisdiction under Section 251 and must be addressed through other provisions.

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