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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 195 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


Reassessment Quashed for Failure to Record Reasons Under Section 148: ITAT Mumbai

January 23, 2026 378 Views 0 comment Print

The issue was whether reassessment is valid when reasons for reopening are not placed on record. The Tribunal held that non-recording of reasons under Section 148(2) vitiates jurisdiction, rendering the reassessment void.

Section 163 Inapplicable Without Direct or Indirect Income Flow to NRI: ITAT Hyderabad

January 22, 2026 861 Views 0 comment Print

This ruling clarifies that an assessee can be treated as an agent of a non-resident only if income is received directly or indirectly for the NRI. In the absence of such receipt or business connection, representative assessment fails.

ITAT Delhi Quashes Search Assessments for Mechanical Approval u/s 153D; Entire Proceedings Held Non-Est

January 22, 2026 687 Views 0 comment Print

The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.

Reassessment Quashed for Invalid Sanction u/s 151: Approval by PCIT Instead of PCCIT Held Void

January 22, 2026 1065 Views 0 comment Print

The reassessment was challenged for lacking approval from the correct authority under Section 151 after three years. The Tribunal held that sanction by an incorrect authority vitiates jurisdiction, rendering the reassessment void.

Section 143(3) Order Invalid as Assessment Had Abated on Search Date

January 22, 2026 1041 Views 0 comment Print

The Tribunal ruled that completion of assessment after search, despite statutory abatement, is impermissible. Jurisdiction shifts exclusively to Section 153A proceedings.

Reassessment Beyond 3 Years Upheld as Escapement Exceeded ₹50 Lakh — Cash Deposits u/s 69A

January 22, 2026 390 Views 0 comment Print

The issue was whether reassessment after three years was barred by limitation. The Tribunal held it valid since the escaped income exceeded ₹50 lakh, attracting the extended reopening window.

Vague Penalty Notice Makes Section 271(1)(c) Proceedings Void: ITAT Rajkot

January 22, 2026 357 Views 0 comment Print

The issue was whether a penalty can survive when the notice does not specify the exact charge. The Tribunal held that a vague notice vitiates the entire penalty proceedings, even where AMT liability exists.

Reassessment Quashed for Service of SCN at Old Email Address

January 22, 2026 459 Views 0 comment Print

The court set aside reassessment proceedings after finding doubt over valid service of notices. Failure to ensure proper communication denied the assessee a fair hearing.

Bogus Share Deals: Section 68 Addition Limited to 2% Commission

January 22, 2026 543 Views 0 comment Print

ITAT ruled that principal amounts in accommodation share entries do not constitute income of a conduit entity. Taxability is restricted to the commission earned for facilitating such transactions.

ITAT Mumbai Allowed Section 54F Claim in Appeal although Not Made in Return

January 22, 2026 2289 Views 0 comment Print

It was ruled that the bar on fresh claims applies only to assessing officers, not appellate bodies. A valid Section 54F claim must be examined on merits during appeal.

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