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Section 148

Latest Articles


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


Accrued MACT Interest Cannot Be Taxed When Award Is Under Appeal

January 9, 2026 522 Views 0 comment Print

Where compensation and interest are deposited under judicial custody due to a pending appeal, no real income accrues. The Tribunal ruled that taxing such MACT interest is impermissible until actual receipt.

Reassessment After Four Years Invalid for Change of Opinion: ITAT Chennai

January 8, 2026 447 Views 0 comment Print

The issue was whether reassessment could be initiated beyond four years after a completed scrutiny assessment. The Tribunal held that reopening was barred as there was no failure to disclose material facts.

Artificial profit/loss arising from client code modification requires transaction-wise reconciliation-Matter restored

January 8, 2026 399 Views 0 comment Print

ITAT Mumbai held that artificial profits or losses arising from Client Code Modification in share transactions carried out in F&O segment requires transaction-wise reconciliation. Accordingly, matter restore to the file of AO.

Reassessment Notice Quashed as Time-Barred After Supreme Court Ruling

January 8, 2026 762 Views 0 comment Print

The issue was whether a reassessment notice issued after the surviving limitation period was valid. The Tribunal held the notice time-barred in light of the Supreme Court ruling, rendering the entire reassessment invalid.

CIT(A) Remand Invalid for Not Deciding Legal Grounds

January 8, 2026 576 Views 0 comment Print

The Tribunal ruled that appellate authorities must adjudicate each legal and factual ground raised in appeal. A mere remand to the AO without deciding jurisdictional issues violates statutory requirements.

Section 68 Addition Deleted as No Credit Entry Found in Books

January 8, 2026 681 Views 0 comment Print

The Tribunal held that Section 68 cannot be invoked unless a sum is found credited in the assessees books. In the absence of any such entry, the addition based on an alleged cash loan was deleted.

Faceless CIT(A) Cannot Reject Appeal for Admitted Tax Payment Lapse: ITAT Raipur

January 8, 2026 336 Views 0 comment Print

The ruling clarifies that the power to admit or reject appeals under section 249(4) lies with NFAC/RFAC, not the Appeal Unit. Appeals were restored due to improper exercise of jurisdiction.

Reopening Quashed as Limitation Under Old Regime Expired: ITAT Mumbai

January 8, 2026 597 Views 0 comment Print

The issue was whether a reassessment notice for AY 2015–16 issued after 31 March 2022 was valid. The Tribunal held the notice time-barred and quashed the entire reassessment proceedings.

Survey-Based Additions Set Aside Due to Lack of Effective Hearing

January 8, 2026 183 Views 0 comment Print

The ITAT held that additions based on survey material cannot be sustained without proper opportunity of hearing. The matter was remitted for fresh adjudication after finding violation of natural justice.

Post-2021 Reassessment Held Void Due to Non-Compliance With Section 148A

January 8, 2026 720 Views 0 comment Print

ITAT Hyderabad held that notices under Section 148 issued on 01.04.2021 without following mandatory Section 148A procedures are invalid. The Tribunal quashed reassessment orders, emphasizing that procedural compliance is jurisdictional and essential.

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