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Section 148

Latest Articles


Bombay HC Invalidates Reassessment Notice for AY 2015-16: Lack of DIN & Jurisdictional Issue

Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...

July 6, 2024 834 Views 0 comment Print

Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Wrong SFT Reporting may invite Notice U/s 148A of Income Tax Act, 1961

Income Tax : Discover the consequences of incorrect SFT reporting triggering U/s 148A notices under the Income Tax Act, 1961. Learn from a deta...

February 27, 2024 3453 Views 0 comment Print

Proposed Penal Provision For Non Registration of Machines In GST

Goods and Services Tax : Explore the proposed penalties in Finance Bill 2024 for non-registration of machines under GST. Analysis of Section 122A and the i...

February 13, 2024 5004 Views 0 comment Print


Latest News


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 6453 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 6936 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 12900 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 41382 Views 2 comments Print

Recall section 148 issued notice under old law after 31.03.2021

Income Tax : DTPA has made a representation to Finance Minister, Smt. Nirmala Sitharaman and requested for for recalling notices under section...

July 5, 2021 21189 Views 3 comments Print


Latest Judiciary


Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 66 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 126 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 261 Views 0 comment Print

Non-Filing of GST Return by Supplier – Assessment Reopening Validity- ITAT Mumbai Order

Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...

July 17, 2024 747 Views 0 comment Print

Section 153A: No Additions Without Incriminating Material for Completed Assessments

Income Tax : Delhi High Court dismisses Income Tax Department's appeal in PCIT Vs Satya Prakash Gupta case, finding no evidence of commission r...

July 16, 2024 207 Views 0 comment Print


Latest Notifications


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 12378 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 3063 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 5337 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 2934 Views 0 comment Print

Carry out due verification before initiating Section 148/147 proceedings: CBDT

Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...

August 22, 2022 13359 Views 0 comment Print


Investment in shares of Agile by Blackstone – HC set-aside Section 148A(d) order

January 29, 2023 1281 Views 0 comment Print

According to HC, the central issue, to which the Assessing Officer (AO) should have applied his mind is, as to whether the investment in shares of Agile by the petitioner was a capital account transaction, given the fact that there is no allegation of round-tripping.

Writ jurisdiction should not substitute findings of an AO with its own: HC

January 29, 2023 945 Views 0 comment Print

HC held that Writ Court should not in exercise of its writ jurisdiction should substitute the findings of an assessing officer in his order with its own.

Writ Jurisdiction of HC cannot be invoked on the ground that reasons recorded are not well-reasoned

January 23, 2023 357 Views 0 comment Print

Lakshya Vintrade Private Limited Vs Union of India And Ors. (Calcutta High Court) The sole ground by the petitioner for challenging the impugned order under Section 148A(d) of the Act is that the same is not a speaking order and the reasons recorded therein are not well-reasoned and satisfactory which according to me cannot be […]

Reopening of assessment sustained due to failure of true & full disclosure

January 23, 2023 759 Views 0 comment Print

Gujarat High Court held that reopening of assessment sustainable on failure of true and full disclosure of demanded material on the part of the petitioner.

Re-opening of assessment in absence of any new tangible material is unsustainable

January 23, 2023 1161 Views 0 comment Print

Bombay High Court held that in absence of any receipt of new information or reference to any new material on record, it can be concluded that re-opening of assessment is merely because of change of opinion and the same is unsustainable in law.

Fictitious transaction requires full-fledged investigations – Writ not maintainable

January 20, 2023 3063 Views 0 comment Print

HC should not interfere in these types of cases where full-fledged investigations are required on alleged fictitious transaction/claim and all these are matters of evidence which cannot be appreciated by the writ court.

Reassessment only on account of ‘change of opinion’ is liable to be struck down

January 19, 2023 1083 Views 0 comment Print

Rajasthan High Court held that reassessment resorted only on account of ‘Change of opinion’ of AO and without there being any fresh tangible evidence for reopening the assessment proceedings is liable to be struck down.

Re-opening of assessment unjustified as complete disclosure of primary material facts already submitted

January 19, 2023 732 Views 0 comment Print

Bombay High Court held that re-opening of assessment under section 147 of the Income Tax Act is unjustified as the assessee provided complete disclosure of all the primary material facts during the scrutiny assessment.

Re-opening of assessment merely based on information from DGIT(Inv.) is untenable

January 19, 2023 1284 Views 0 comment Print

ITAT Mumbai held that re-opening of assessment without ‘reason to believe’ simply based on the information from DGIT(Inv.) is untenable in law.

Relaxation Act 2020- 6 Year Limitation for Reassessment notice – Approving Authority

January 19, 2023 1239 Views 0 comment Print

MA Multi-Infra Development Pvt. Ltd. Vs ACIT (Bombay High Court) On a perusal of the notice dated 31st March 2021 issued u/s.148 of the Act by the Assessing Officer shows that the same has been issued after obtaining necessary satisfaction of the Range 3(2), Mumbai. As per the objections filed by the revenue, the approval […]

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