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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


Wrong Section (69A vs 68) Not Fatal – Accommodation Entry Addition Sustained by ITAT

March 19, 2026 1326 Views 0 comment Print

The Tribunal ruled that incorrect invocation of Section 69A does not invalidate the addition. Since the loan was found to be an accommodation entry, it was sustained under Section 68. The decision emphasizes substance over technical defects.

Section 68 Addition Deleted as AO Relied Only on Suspicion & Third-Party Material

March 19, 2026 924 Views 0 comment Print

ITAT held that the assessee discharged the burden of proving identity, creditworthiness, and genuineness. Addition was deleted as AO relied only on suspicion without evidence.

PAN Misuse Allegation – ITAT Remands Matter to Verify Police Report; Relief Possible if Misuse Proven

March 19, 2026 681 Views 0 comment Print

ITAT remanded the matter where the assessee claimed PAN misuse leading to additions under Sections 68 and 69. It directed AO to verify the police report, holding that relief must be granted if misuse is substantiated.

No digital/physical signatures of approving authority – Section 148 notice quashed

March 19, 2026 1458 Views 0 comment Print

The Tribunal held reassessment invalid as no proper sanction under Section 151 was produced. The notice under Section 148 was quashed, making all additions unsustainable.

Reopening Quashed: Non-Compliance with GKN Driveshafts Procedure Vitiates Entire Assessment

March 18, 2026 486 Views 0 comment Print

The case addressed whether reassessment can proceed before disposing of objections. The Tribunal ruled that such action breaches mandatory legal procedure, leading to quashing of the assessment.

Exemption Allowed as Corpus Donations Excluded from Annual Receipts U/s. 10(23C)(iiiad)

March 18, 2026 468 Views 0 comment Print

The Tribunal held that corpus donations received with specific directions are capital in nature and cannot be included in annual receipts. Since actual receipts were below ₹1 crore, exemption was allowed.

Stamp Duty Addition Deleted – Allotment Date Prevails for Sec 56(2)(x) Valuation

March 18, 2026 423 Views 0 comment Print

ITAT held that stamp duty value on registration date cannot be applied where allotment occurred earlier. Allotment date determines valuation under Section 56.

Reassessment u/s. 148 after four years untenable as full and true material facts disclosed

March 18, 2026 396 Views 0 comment Print

ITAT Chennai held that reassessment u/s. 148 of the Income Tax Act after expiry of four years not sustainable since there was no failure on the part of assessee to disclose fully and truly all material facts. Further, reassessment is invalid for non-furnishing of actual reasons recorded.

ITAT Kolkata quashed Reassessment as Time-Barred Due to Expiry of Limitation Period

March 18, 2026 456 Views 0 comment Print

The Tribunal examined whether reassessment proceedings were valid when initiated beyond the statutory time limit. It held that the notice issued under Section 148 was barred by limitation and invalid. The ruling emphasizes strict adherence to limitation provisions in reassessment cases.

Section 69A Addition Deleted as Cash Withdrawals Were from Disclosed Bank Accounts: ITAT Mumbai

March 18, 2026 867 Views 0 comment Print

The ITAT held that no addition can be made under Section 69A when the source of cash is explained through bank withdrawals. Doubts about utilisation alone cannot justify treating it as unexplained money.

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