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Section 148

Latest Articles


A comprehensive analysis of function of electronic information in tax assessments

Income Tax : Explore how electronic data transforms tax assessments, highlighting accuracy issues, verification needs, and taxpayer rights as s...

August 7, 2024 873 Views 0 comment Print

Note on Income Tax Notices Issued: Section148 read with Section 135A

Income Tax : Learn about the revised procedure for reopening cases under Section 148 RWS 135A and the implications of Finance Act 2021, includi...

July 31, 2024 2634 Views 0 comment Print

Budget 2024: Rationalization of Income Tax Re-assessment Provisions

Income Tax : Discover the key amendments in the Finance (No.2) Bill, 2024, affecting income tax reassessment procedures under the Income-tax Ac...

July 25, 2024 1164 Views 0 comment Print

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 1005 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 1629 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 546 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 1080 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 6483 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 6954 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 12915 Views 0 comment Print


Latest Judiciary


Passing of order u/s. 148A(d) on the basis of fresh ground untenable: Delhi HC

Income Tax : Delhi High Court held that passing of order by the revenue under section 148A(d) of the Income Tax Act on the basis of fresh groun...

August 17, 2024 195 Views 0 comment Print

Addition u/s. 68 justified as genuineness of transaction and creditworthiness of creditors not proved: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that genuineness of transaction, creditworthiness and identity of creditors not proved, hence addition u/s. 68...

August 17, 2024 102 Views 0 comment Print

Advance tax payment provisions doesn’t apply in reassessment proceedings: ITAT Indore

Income Tax : ITAT Indore held that rejection of appeal by CIT(A) on the footing of non-payment of advance tax as required by section 249(4)(b) ...

August 17, 2024 90 Views 0 comment Print

Notice u/s. 148 to NRI without following mandatory faceless procedure unsustainable: Telangana HC

Income Tax : Telangana High Court held that notice issued u/s. 148 of the Income Tax Act must comply with the requirement of the Scheme whether...

August 17, 2024 447 Views 0 comment Print

Notice u/s. 148A issued by Jurisdictional AO instead of Faceless AO liable to be quashed: Bombay HC

Income Tax : Bombay High Court held that issuance of notice under section 148A of the Income Tax Act by Jurisdictional Assessing Officer and no...

August 17, 2024 762 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 15774 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 3288 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 5376 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 2952 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 13533 Views 0 comment Print


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 1296 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 1263 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 […]

Reopening of assessment for mere change of opinion untenable in law

January 17, 2023 2415 Views 0 comment Print

Gujarat High Court held that issued raised in reopening assessment was already considered during assessment proceedings u/s 143(3) of the Income Tax Act. Accordingly, mere change of opinion by the Assessing Officer cannot be ground for reopening of assessment.

Validity of Second notice issued under Section 148 of Income Tax Act without disposing return filed to first notice

January 16, 2023 8139 Views 0 comment Print

A short question of law involved in this writ petition is that whether a second notice under Section 148 of the Income Tax Act, 1961 issued by the assessing officer after the expiry of one year as per Section 153(6)(i) is valid without disposing the return filed to the first notice issued under Section 148 of the Income Tax Act for the very same assessment year.

Analysis of 4 Recent Important Income Tax Case laws

January 16, 2023 16146 Views 1 comment Print

Learn about a Gujarat High Court case on reopening of income tax re-assessment proceedings under the Finance Act 2021. Analysis of 4 Recent Important Income Tax Case laws

HC can entertain Writ Petition to Examine if Conditions to issue Section 148 Notice are Satisfied: SC

January 15, 2023 2583 Views 0 comment Print

Red Chilli International Sales Vs ITO (Supreme Court of India) We with the petitioner that the impugned judgment rejecting the writ petition on the ground of alternative remedy does not take into consideration several judgments of this Court, on the jurisdiction of High Court, as writ petitions have been entertained to be examined whether the […]

Reasonableness of Notices issued under section 148 of Income Tax Act

January 15, 2023 10989 Views 1 comment Print

Evaluate the reasonableness of Notices issued under section 148 of Income Tax Act, as amended in the Finance Act 2021. Get to know the time limits for issuing a Reassessment Notice.

Reopening of assessment for contingent nature of addition unsustainable

January 10, 2023 3573 Views 0 comment Print

ITAT Kolkata held that addition cannot be made on protective basis in the reopened assessment proceeding as the assessment cannot be reopened for a contingent nature of addition.

Assessee can challenge reopening notice at the stage of challenging consequential Assessment order: HC

January 10, 2023 2478 Views 0 comment Print

Auroglobal Comtrade Private Limited Vs Chairman, CBDT & Others (Orissa High Court) HC declined to accept challenge to the Reopening notices under Section 148-A(1)(b) of the Act as well as the consequential order under Section 148-A(1)(d) of the Act by holding that the Petitioners/Assessees in those cases would have a full opportunity of urging all […]

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