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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


Reopening under Section 147 Invalid Where Search Material Triggers Section 153C

January 29, 2026 1134 Views 0 comment Print

The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.

On-Money Additions Deleted: Loose Digital Data & Third-Party Statements Not Enough

January 29, 2026 1230 Views 0 comment Print

ITAT ruled that unverified electronic records recovered from a third party do not constitute reliable evidence of cash payments. Additions based solely on such data were deleted.

Section 69A Addition Quashed Where Presumptive Income Was Declared

January 29, 2026 1311 Views 0 comment Print

The Tribunal held that receipts already offered under the presumptive scheme cannot be taxed again as unexplained money. Once income is declared under section 44AD and supported by surrounding facts, section 69A has no application.

Mere Claims of Cheque Discounting Insufficient to Explain Bank Credits: ITAT Surat

January 28, 2026 1293 Views 0 comment Print

The Tribunal upheld the remand of an ex parte assessment where substantial bank deposits were not supported by any documentary evidence. It held that unsupported explanations cannot replace proof, and fresh verification by the Assessing Officer was necessary.

Delhi HC Quashed Reassessment Notice as Time-Barred for Crossing Ten-Year Limit

January 28, 2026 732 Views 0 comment Print

Reassessment was struck down as no satisfaction note by the searched person’s AO was shown. The ruling reiterates that limitation cannot be bypassed through procedural shortcuts.

Bogus Purchases Can’t Be Added in Full When Sales Are Accepted: ITAT Restricts Addition to 3% GP

January 28, 2026 624 Views 0 comment Print

The case examined the tax treatment of purchases from alleged accommodation entry providers. The Tribunal held that at best, only the profit element embedded in such purchases can be brought to tax.

Section 271(1)(c) Penalty Cannot Survive When Reassessment Is Quashed: ITAT Chennai

January 28, 2026 933 Views 0 comment Print

The ITAT held that when reassessment is annulled for jurisdictional defects under the faceless regime, the connected concealment penalty cannot stand.

CIT(A) Cannot Bypass Jurisdictional Grounds by Simple Remand: ITAT Amritsar

January 28, 2026 339 Views 0 comment Print

The issue was whether the appellate authority could bypass jurisdictional objections by remanding the case. The tribunal held that legal grounds striking at jurisdiction must be adjudicated first.

Suspicion Cannot Replace Evidence, Ad-Hoc Commission Addition Partly Set Aside

January 27, 2026 411 Views 0 comment Print

The Tribunal held that additions based solely on third-party GST information and suspicion cannot be sustained without independent investigation, restricting estimation to 1% of sales.

Redevelopment Compensation is Capital Receipt, Not Taxable as Income: ITAT Mumbai

January 27, 2026 1686 Views 0 comment Print

The Tribunal ruled that compensation and hardship allowance received during redevelopment are capital receipts and cannot be taxed as income from other sources.

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