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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 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


Borrowed Satisfaction from Investigation Wing Not Permissible

January 15, 2026 1227 Views 0 comment Print

The Tribunal ruled that reassessment based on borrowed satisfaction, without inquiry or verification by the AO, is unsustainable. Independent application of mind is mandatory under the new regime.

Cash Deposit Reassessment Set Aside for Lack of Valid Sanction: ITAT Delhi

January 15, 2026 1542 Views 0 comment Print

Despite large additions for alleged unexplained cash deposits, the Tribunal quashed the reassessment itself. It reaffirmed that jurisdiction cannot be assumed without proper and reasoned approval.

LTCG on Firm Dissolution Sent Back for Fresh Verification

January 15, 2026 492 Views 0 comment Print

The Tribunal held that deletion of long-term capital gains without examining original partnership records was premature. The matter was remanded for fresh verification of facts and documents.

Electronic Evidence Requires Cross-Examination Before Addition: ITAT Delhi

January 15, 2026 384 Views 0 comment Print

The Tribunal held that additions based solely on third-party statements and seized digital data cannot survive without allowing cross-examination. The matter was remanded for fresh adjudication after granting due opportunity to the assessee.

Unexplained Investment Limited to Actual Payment Made in the Year: ITAT Mumbai

January 15, 2026 795 Views 0 comment Print

The Tribunal ruled that additions under section 69 cannot exceed the amount actually invested during the relevant year. Where most payments were loan-funded, only the year-specific payment required examination.

Reopening After 3 Years Barred If Escapement Below ₹50L: ITAT Delhi

January 15, 2026 897 Views 0 comment Print

ITAT Delhi quashed reassessment issued beyond three years where alleged escapement was only ₹35 lakh. Section 149 bars reopening unless the ₹50-lakh threshold is satisfied.

No Valid U/s 143(2) Notice: Reopening Proceedings Void: ITAT Delhi

January 15, 2026 453 Views 0 comment Print

The Tribunal held that reassessment is invalid where the mandatory notice under Section 143(2) is issued beyond the prescribed time limit. Absence of a valid and timely notice strikes at the very jurisdiction of the Assessing Officer.

Mechanical Sanction Voids Reopening Under Section 147: ITAT Delhi

January 15, 2026 819 Views 0 comment Print

ITAT Delhi held that reassessment based on mechanical approval is invalid in law. Sanction must reflect independent application of mind by the approving authority.

Section 148 Notice Issued Beyond Surviving Time Invalid: ITAT Delhi

January 15, 2026 1086 Views 0 comment Print

The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.

Telangana HC Quashes Section 148 Unsigned Reassessment Notice

January 15, 2026 567 Views 0 comment Print

The High Court held that a reassessment notice issued without a manual or digital signature violates Section 282A of the Income-tax Act. Such an unsigned notice is invalid in law, rendering all consequential proceedings unsustainable.

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