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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


Search Assessment – Telescoping Upheld, No Double Taxation & U/s 234A Interest Curtailed

February 6, 2026 444 Views 0 comment Print

The tribunal held that amounts already disclosed and taxed as accommodated receipts cannot be taxed again under another head. Separate additions were deleted as they resulted in impermissible double taxation.

Re-assessment U/s 147 Quashed as Time-Barred — Stay Period Ends on Date of Vacation, Not Communication

February 6, 2026 501 Views 0 comment Print

The issue was whether reassessment completed after a court stay complied with statutory timelines. The Tribunal held that limitation resumes from the date the stay is vacated, rendering the reassessment time-barred.

Borrowed Satisfaction from Insight Portal Invalid; Re-opening Section 68 Addition Quashed

February 6, 2026 738 Views 0 comment Print

The issue was whether reopening based only on portal information is valid. The Tribunal held that absence of independent inquiry and tangible material vitiates reassessment and nullifies the addition.

Section 148 Notice Served on 01-04-2021 Invalid; Re-opening Quashed for Non-Compliance with 148A

February 6, 2026 819 Views 0 comment Print

ITAT Surat held reassessment invalid where notice u/s 148, though dated 31-03-2021, was issued on 01-04-2021 without following s.148A procedure; entire reassessment quashed.

Section 56(2)(vii)(b) Automatic, but DVO Reference Mandatory When Valuation Disputed

February 5, 2026 741 Views 0 comment Print

The Tribunal held that section 56(2)(vii)(b) applies automatically when stamp value exceeds purchase price. However, it remanded the matter for DVO valuation to ensure fair determination of market value.

No Tangible Material: Reassessment Invalid; Bogus LTCG Addition Deleted– ITAT Chandigarh

February 5, 2026 702 Views 0 comment Print

Since the reassessment itself was quashed, the addition treating long-term capital gains as unexplained cash credit under section 68 automatically failed. Jurisdictional defects were fatal to the assessment.

Reassessment u/s 148 Quashed Where No Addition Made on Recorded Reasons: ITAT Cuttack

February 5, 2026 1587 Views 0 comment Print

ITAT Cuttack held that reassessment proceedings fail when no addition is made on the very reasons recorded for reopening. If the original ground disappears, the entire reassessment becomes invalid.

Section 37 Relief Granted Because Payment Was Not Hit by Pre-2015 CSR Bar

February 5, 2026 375 Views 0 comment Print

The ruling clarifies that CSR-related disallowance under Section 37(1) applies only from AY 2015-16 onwards. For earlier years, expenses with a business nexus remain deductible.

Budget 2026: Analysis of Key Proposals related to Income Tax Act, 1961 

February 5, 2026 6129 Views 0 comment Print

The Budget introduces extended timelines, updated-return flexibility, and fewer prosecutions. The key takeaway is a shift from punishment to voluntary compliance.

Survey Admission Alone Cannot Justify Full Disallowance: ITAT Chennai Restricts Land Development Expense Disallowance to 10%

February 5, 2026 249 Views 0 comment Print

The Tribunal held that additions based solely on a survey statement, without corroborative evidence, are unsustainable. Development expenses were largely allowed, with only a reasonable estimated disallowance retained.

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