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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 Quashes Reassessment as AO Changed Reason from Fake Loan Entries to Penny Stock LTCG

May 17, 2026 3201 Views 0 comment Print

The ITAT Ahmedabad held that reassessment under Section 147 was invalid because the Assessing Officer reopened the case for fictitious loan entries but made additions for alleged bogus LTCG from penny stock transactions. The Tribunal ruled that changing the basis of reopening is not permissible in law.

Assessment Upheld as Material Seized in Search Can Be Used Even if Search Is Later Challenged

May 17, 2026 186 Views 0 comment Print

The Delhi High Court held that material recovered during a search can validly form the basis of reassessment proceedings even if the search is later alleged to be illegal. The Court ruled that proceedings initiated on the basis of such material do not automatically become void.

Kerala HC Upholds Rejection of Delayed Income Tax Refund Claim Due to Five-Year CBDT Limit

May 17, 2026 360 Views 0 comment Print

The Kerala High Court held that delay condonation applications under Section 119(2)(b) must comply with the revised five-year limitation prescribed by CBDT circulars. The Court ruled that authorities cannot entertain applications filed beyond the revised period.

Accrued Income Cannot Be Deferred Just Because Receipt Is Delayed – ITAT Upholds Taxability on Mercantile Basis

May 16, 2026 93 Views 0 comment Print

The Tribunal ruled that an assessee following mercantile accounting must offer interest income to tax on accrual basis, irrespective of delayed receipt. Failure to disclose the full accrued amount in the relevant year justified reassessment and addition.

Section 68 Addition Crashes – ITAT Mumbai Says Suspicion & Investigation Wing Reports Cannot Replace Evidence

May 16, 2026 150 Views 0 comment Print

ITAT Mumbai held that additions under section 68 cannot survive where the Assessing Officer failed to conduct independent verification of alleged accommodation entries. Reliance solely on third-party investigation reports was rejected.

ITAT Deletes Bogus Purchase Addition as No Evidence Linked Assessee to Alleged Accommodation Entries

May 15, 2026 1302 Views 0 comment Print

ITAT Ahmedabad held that reassessment under Section 147 was invalid as the Assessing Officer failed to show independent application of mind or establish a nexus between investigation material and escaped income.

Delhi HC Rejects Reassessment as AO Repeated Additions Already Set Aside by CIT(A)

May 15, 2026 153 Views 0 comment Print

The Delhi High Court held that reassessment proceedings under Section 148 were invalid where the Assessing Officer sought to make the same additions already annulled by the CIT(A). The Court upheld the Tribunal’s decision quashing the reassessment order.

Calcutta HC Quashes Reassessment Due to Mere Suspicion Without Independent Inquiry

May 15, 2026 237 Views 0 comment Print

The Calcutta High Court held that reassessment proceedings cannot be reopened merely on suspicion arising from investigation reports. The Court ruled that “reason to believe” must be based on independent application of mind and material evidence.

Third-Party Loose Papers Cannot Justify Addition Without Cross-Examination: ITAT Delhi

May 15, 2026 375 Views 0 comment Print

ITAT Delhi ruled that reassessment in search cases requires prior approval under section 148B before passing the order. Since the department failed to obtain the prescribed approval, the assessment was quashed as invalid in law.

Bombay HC Quashes Reassessment Due to Approval by Wrong Authority

May 15, 2026 285 Views 0 comment Print

The Bombay High Court held that reassessment proceedings issued beyond three years for AY 2018-19 were invalid because approval was granted by the Principal Commissioner instead of the competent authority under Section 151(ii).

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