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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


Reopenings for AYs 2014-15 & 2015-16 Time-Barred: ITAT Quashes Section 148 Notices

January 20, 2026 792 Views 0 comment Print

ITAT held that reassessment notices issued after the permissible limitation period were invalid. Applying the Supreme Court’s ruling in Rajeev Bansal, all proceedings were quashed as being beyond jurisdiction.

Section 263 Revision Upheld for Failure to Tax Interest on Enhanced Compensation

January 20, 2026 579 Views 0 comment Print

The Tribunal held that the Assessing Officer failed to apply amended provisions taxing interest on enhanced compensation. Revision under Section 263 was upheld as the assessment was erroneous and prejudicial to revenue.

Political Donation Disallowance Set Aside for Borrowed Satisfaction & Natural Justice Violation

January 20, 2026 1212 Views 0 comment Print

The Tribunal sustained reassessment based on search information but faulted the disallowance of political donations. The key takeaway is that additions cannot rest solely on untested third-party statements without cross-examination.

Rajeev Bansal Rulling Applies: SC Dismisses Revenue Appeal on Income Tax Reassessment Notices

January 20, 2026 825 Views 0 comment Print

The SC dismissed Revenue appeals holding reassessment notices unsustainable as the issue stood concluded by an earlier binding judgment. The ruling reinforces adherence to settled law in reopening cases.

Bombay HC Quashed Reassessment for Being Covered by Prior HC Ruling

January 20, 2026 360 Views 0 comment Print

The court set aside reassessment orders and notices as the issue was already covered by an earlier judgment. Consequential proceedings were also nullified, with other rights kept open.

Mere “Approved” Not Enough: ITAT Voids Reopening for Mechanical Sanction

January 20, 2026 417 Views 0 comment Print

The Tribunal held that reassessment was invalid as the statutory sanction under Section 151 was granted mechanically. Mere use of the word Approved does not show application of mind and vitiates the entire proceedings.

Reassessment Quashed for Mechanical Section 151 Approval: ITAT Delhi

January 20, 2026 744 Views 0 comment Print

The Tribunal held that sanction for reopening was granted mechanically and without independent application of mind, as required under Section 151. An undated and non-speaking approval vitiated the entire reassessment proceedings.

Reassessment Quashed: Undated PCIT Approval Invalid u/s 151

January 20, 2026 465 Views 0 comment Print

Failure to demonstrate a dated approval under Section 151 proved fatal to the Revenue’s case. The decision underscores strict compliance in reopening assessments.

Entire Reopening Invalid Due to Lack of Proof of Section 148 Notice Service: ITAT Delhi

January 20, 2026 279 Views 0 comment Print

The assessment was set aside as the Revenue produced no acknowledgment of service. The ruling reiterates that service of notice is foundational to reassessment.

Reassessment Quashed for Non-Issuance of Mandatory Section 143(2) Notice

January 20, 2026 603 Views 0 comment Print

The Tribunal held that reassessment under Sections 147/144B is void if no notice under Section 143(2) is issued. Acting on a return filed or adopted in response to Section 148 triggers mandatory jurisdictional compliance.

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