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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 14061 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 2826 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 1056 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: ITAT Delhi

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 282 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 690 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 58941 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


Unsecured Loan Addition u/s 68 Deleted – Filatex Group Loans Held Genuine

February 14, 2026 489 Views 0 comment Print

ITAT Delhi upheld deletion of ₹60 lakh addition after finding that the assessee furnished confirmations, audited financials, bank statements, and Section 133(6) replies. In absence of direct evidence linking loans to accommodation entries, the addition under Section 68 was held unsustainable.

Assessment Quashed – Order by Non-Jurisdictional AO Void ab Initio: ITAT Chennai

February 14, 2026 552 Views 0 comment Print

The Tribunal held that statutory jurisdiction must be strictly followed in income-tax proceedings. In absence of proof of transfer to the assessing ward, the assessment was declared invalid and set aside.

Foreign HSBC Account Addition Deleted – BUP ID & Base Note Insufficient: ITAT Mumbai

February 14, 2026 699 Views 0 comment Print

The Tribunal held that failure to provide opportunity to cross-examine foreign information sources amounted to violation of natural justice. Additions based on unverified documents were therefore invalid.

Excess stock addition restricted – Survey working flawed; only disclosed difference taxable – ITAT Bangalore

February 14, 2026 369 Views 0 comment Print

The Tribunal ruled that incorrect computation of opening and closing stock during survey cannot justify full addition. Only the reconciled excess stock amount already offered to tax was sustained.

Reassessment Quashed – Invalid Sanction u/s 151(ii) by PCIT After 3 Years: ITAT Chennai

February 14, 2026 483 Views 0 comment Print

Where more than three years had elapsed, approval from the higher specified authority was compulsory before issuing notice. Failure to obtain such approval vitiated the reassessment proceedings.

Reopening invalid – Failure to supply material u/s 148A(b) violates natural justice; assessment quashed – ITAT Mumbai

February 14, 2026 909 Views 0 comment Print

Citing judicial precedents, the Tribunal held that failure to provide underlying material before passing order under Section 148A(d) invalidates reopening. The assessment order was consequently quashed.

Reassessment notice u/s 148 quashed – Income below ₹50 lakh wrong sanctioning authority – ITAT Mumbai

February 14, 2026 11451 Views 0 comment Print

The ITAT Mumbai held that reassessment notice issued beyond three years is invalid where alleged escaped income is below ₹50 lakh. Non-compliance with amended section 151 rendered the notice and entire proceedings void.

Penny Stock Addition u/s 68 Set Aside; Reopening Held Invalid for lack of Mind Application

February 13, 2026 732 Views 0 comment Print

The Tribunal emphasized that approval from the correct specified authority is mandatory where reopening exceeds three years. Failure to comply rendered the reassessment proceedings void ab initio.

Section 69A Addition Deleted & Reopening Quashed – No Ownership of Money & Borrowed Satisfaction

February 13, 2026 1452 Views 0 comment Print

The Tribunal held that reassessment beyond four years is invalid where the assessee had fully disclosed material facts during original scrutiny. In absence of failure to disclose, reopening under Section 147 was quashed.

Reassessment Quashed – Invalid Approval U/s 151 Vitiates Jurisdiction

February 13, 2026 1512 Views 0 comment Print

The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.

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