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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 273 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 657 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 291 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 58938 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


Addition U/s 69 Deleted; AO/CIT(A) Inconsistency & No On-Money Evidence – ITAT Mumbai

February 21, 2026 714 Views 0 comment Print

ITAT deleted ₹14.74 lakh addition as identical source was accepted in spouse’s case. Alleged on-money payment lacked corroborative evidence.

Registration Not Determinative; Stock-in-Trade Taxable on Possession & Consideration – Rs 10.81 Cr Deleted – ITAT Mumbai

February 21, 2026 372 Views 0 comment Print

Tribunal ruled that once consideration was received and possession handed over in an earlier year, subsequent registration cannot shift taxability. Revenue’s reliance on Insight Portal data was rejected.

Reopening Quashed – Sec 151 Approval by PCIT Invalid Beyond 3 Years; Reassessment Void – ITAT Mumbai

February 21, 2026 762 Views 0 comment Print

The ITAT Mumbai held that reassessment initiated beyond three years was invalid as approval under Section 151 was granted by the Principal Commissioner instead of the statutorily required Principal Chief Commissioner or equivalent authority.

Reassessment Quashed: Sec 143(2) Notice Mandatory in 147 Cases; Return Filed Within TOLA Time Valid – ITAT Kolkata

February 21, 2026 810 Views 0 comment Print

The Tribunal ruled that failure to issue notice under Section 143(2) after receiving return in reassessment proceedings is a jurisdictional defect. The reassessment order was quashed.

Reassessment Beyond 3 Years Void for PCIT Approval Instead of PCCIT – ITAT Mumbai

February 21, 2026 618 Views 0 comment Print

ITAT Mumbai quashed reassessment beyond 3 years as approval under Sec 151(ii) was granted by PCIT instead of PCCIT/CCIT, rendering notice u/s 148 and entire proceedings invalid.

Faceless Assessment Before Sec 151A Notification Held Without Jurisdiction – Entire Assessment Quashed – ITAT Kolkata

February 21, 2026 1215 Views 0 comment Print

ITAT held that though Section 151A was on statute, it required notification to take effect. As the order preceded notification, the assessment was quashed in entirety.

Non-Application of Mind and Wrong AY Render Sec 147 Reopening Void – ITAT Kolkata

February 21, 2026 483 Views 0 comment Print

The Tribunal found repeated factual errors in recorded reasons and notices. As the reopening lacked live nexus with escapement of income, it was struck down as a nullity.

Penalty U/s 271D & 271E Deleted – Partner Capital Cash Not Covered U/s 269SS/269T: ITAT Kolkata

February 21, 2026 2589 Views 0 comment Print

The ITAT Kolkata held that cash introduced by partners as capital contribution in an LLP does not attract Section 269SS and therefore penalty under Section 271D was invalid.

Section 149(1)(b) Conditions Unmet: Reopening and Adhoc Profit Addition Quashed – ITAT Kolkata

February 21, 2026 441 Views 0 comment Print

ITAT ruled that mere reference to high-value transactions cannot justify reopening beyond three years. Absence of statutory conditions under Section 149(1)(b) rendered the reassessment void.

Reopening Beyond 3 Years Quashed: PCIT (Not PCCIT) Approval U/s 151(ii) Invalid – Jurisdictional Defect Fatal – ITAT Kolkata

February 21, 2026 546 Views 0 comment Print

ITAT held that for reassessment beyond three years, approval must be obtained from the PCCIT under Section 151. Sanction from PCIT was held invalid, rendering the notice and assessment void.

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