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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 108 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


ITAT Agra Upholds Separate NP Rates: 0.22% (Animal Trading) & 8.7% (Scrap)

January 22, 2026 339 Views 0 comment Print

The dispute centered on profit estimation after reopening for suppressed turnover. The Tribunal affirmed lower NP for animal sales, recognising industry norms and assessee history. The ruling underscores tailoring estimates to trade economics.

Agricultural Cash Deposits Explained, Section 69A Addition Deleted

January 22, 2026 723 Views 0 comment Print

While reopening of assessment was sustained due to bank deposit information, the cash addition was deleted on merits. Proper explanation of source defeats Section 69A.

ITAT Patna Deletes u/s 69A Addition on Time Deposit; NEFT from Father Explained

January 22, 2026 270 Views 0 comment Print

It was ruled that money received from a parent through banking channels constitutes an explained source. The addition under Section 69A was deleted as the transaction was fully traceable.

Cash Deposit Addition Quashed for Trader Covered by Section 44AD

January 22, 2026 495 Views 0 comment Print

The issue was whether a trader declaring income under Section 44AD could face additions for unexplained cash deposits. The Tribunal ruled in favour of the assessee, holding such additions contrary to law. 

Reassessment Order Struck Down for Jurisdictional Defect

January 22, 2026 894 Views 0 comment Print

The Tribunal held that NFAC had no authority to pass reassessment orders before the faceless reassessment notification became operative. As a result, the entire assessment was quashed. The ruling highlights that participation by the assessee cannot cure jurisdictional defects.

Entire Bogus Purchases Cannot Be Added When Sales Accepted: ITAT Dehradun Restricts Addition to 4%

January 21, 2026 753 Views 0 comment Print

The issue was whether 100% of alleged bogus purchases could be disallowed despite accepted production and sales. The Tribunal held that only the embedded profit element can be taxed, not the entire purchase value.

Only Profit Element Taxable on Cash Deposits & Unsecured Loans: ITAT Rajkot

January 21, 2026 327 Views 0 comment Print

The issue was whether entire cash deposits and unsecured loans could be taxed as unexplained income. The Tribunal held that only the embedded profit is taxable and restricted the addition to 10%.

TP Adjustment Based on DRI Allegations Cannot Survive After Exoneration: ITAT Mumbai

January 21, 2026 498 Views 0 comment Print

The issue was whether a transfer pricing adjustment could survive when based solely on DRI allegations later dropped. The Tribunal held that once customs authorities exonerated the assessee, the TP adjustment had no foundation and was rightly deleted.

Section 148 Notices Void as Issued Outside Mandatory Faceless Scheme

January 21, 2026 534 Views 0 comment Print

The ITAT held that reassessment notices issued by the Jurisdictional AO after 29.03.2022 are void under the faceless regime. Since the assessments were invalid, all consequential penalty orders were also quashed.

ITAT Mumbai Restricts Bogus Purchase Addition to 6%; Full 69C Disallowance Set Aside

January 21, 2026 732 Views 0 comment Print

The issue was whether the entire amount of alleged bogus purchases could be disallowed under Section 69C. ITAT Mumbai held that in the absence of corroborative evidence, only the profit element can be taxed, restricting the addition to 6%.

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