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Section 148

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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


Circular Trading Not Bogus, 12.5% Purchase Addition Deleted

January 27, 2026 471 Views 0 comment Print

It was ruled that the Assessing Officer’s own finding of circular trading negates the application of bogus purchase jurisprudence. In the absence of evidence of sham transactions, estimated profit additions cannot survive.

ITAT Ahmedabad Deletes Section 68 Addition on Alleged Accommodation Sales

January 27, 2026 498 Views 0 comment Print

The Tribunal held that where purchases are not disputed and books are not rejected, the entire sale consideration cannot be added as unexplained income. Since the assessee had already offered profits to tax, the addition was deleted.

Reopening Invalid as JAO Lacked Jurisdiction Under Faceless Scheme

January 27, 2026 708 Views 0 comment Print

It was ruled that reassessment proceedings must be initiated only through the faceless mechanism after the CBDT notification under section 151A. The concept of concurrent jurisdiction between JAO and FAO was expressly rejected.

ITAT Chandigarh Strikes Down Section 147 Proceedings Based on Uncorroborated Third-Party Excel Sheet

January 24, 2026 1350 Views 0 comment Print

The issue was whether reassessment initiated by the Jurisdictional AO was valid. The Tribunal held the notice invalid as it violated mandatory faceless assessment procedures, rendering the reassessment void.

Section 28 Interest Is Compensation, Not Income: Reassessment Set Aside

January 24, 2026 1449 Views 0 comment Print

The Tribunal held that interest under Section 28 is part of compensation and not taxable as other income. A reopening based on such misinterpretation was quashed for lack of valid belief.

Section 271(1)(c) Penalty Fails When AO Accepts Reopened Return

January 24, 2026 552 Views 0 comment Print

The ruling clarifies that once a reassessment return is accepted, earlier returns lose relevance for penalty purposes. In the absence of defects in the reassessment return, penalty cannot survive.

Reassessment Notice & Order Quashed for Denial of Opportunity to Produce Accounts

January 24, 2026 1080 Views 0 comment Print

The issue was whether reassessment could proceed when financial statements were not called for despite the taxpayer’s willingness to furnish them. The court set aside the notice, holding that lack of proper opportunity vitiated the reopening.

Section 80HHC Amendment Non-Retrospective: Delhi HC Quashed Reassessment Notice

January 24, 2026 408 Views 0 comment Print

The Court held that reassessment based on a retrospective amendment to Section 80HHC is invalid. The key takeaway is that such amendments cannot reopen concluded assessments.

Income Tax Reassessment Notice Quashed for Breaching 10-Year Limitation Rule

January 24, 2026 555 Views 0 comment Print

The issue was whether a Section 148 notice for AY 2015-16 issued in August 2024 was time-barred. The Court held it exceeded the ten-year limit and quashed the proceedings.

Reassessment for AY 2015-16 Time-Barred After Rajeev Bansal Ruling: ITAT Kolkata

January 23, 2026 717 Views 0 comment Print

The issue was whether reassessment notices issued after the extended period under TOLA were valid. The Tribunal held that post–Rajeev Bansal, notices beyond the surviving limitation are time-barred and void.

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