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Section 148

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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


Madras HC Quashed Reassessment for Limitation Breach Despite Software Depreciation Dispute

January 8, 2026 435 Views 0 comment Print

The court held that reopening beyond the permissible period was invalid where full disclosures were made and no new material emerged. Reassessment based solely on existing records was ruled time-barred.

Reassessment for A.Y. 2015–16 After 1 April 2021 Void: Bombay HC

January 8, 2026 915 Views 0 comment Print

The High Court quashed a reassessment for A.Y. 2015–16 where the Section 148 notice was issued after 1 April 2021. Relying on the Revenue’s binding concession before the Supreme Court, all consequential actions were set aside.

On-Money Gross Receipts Not Taxable, Only Profit Can Be Assessed

January 6, 2026 3558 Views 0 comment Print

The Revenue sought to tax total on-money collected under section 69A. The ITAT ruled that on-money forms part of business receipts and must be assessed on a profit basis. The key takeaway is that taxation cannot ignore unaccounted expenses linked to such receipts.

ITAT Kolkata Upholds Reopening & Sustains ₹1 Cr Addition u/s 68 on Alleged Accommodation Entry

January 6, 2026 2460 Views 0 comment Print

The Tribunal upheld reassessment based on Investigation Wing material alleging accommodation entries. It ruled that such tangible inputs justified reopening despite a completed scrutiny assessment.

Notice Invalid as Approval Under Section 151(ii) Was Defective: ITAT Raipur

January 6, 2026 621 Views 0 comment Print

The Tribunal held that reassessment initiated beyond three years requires approval from the Principal Chief Commissioner or Chief Commissioner. Sanction granted by the PCIT was invalid, rendering the entire reassessment void.

Form 35 Defect Curable, Dismissal Without Hearing Set Aside

January 6, 2026 420 Views 0 comment Print

The appeals were rejected without examining additions made by the Assessing Officer. The Tribunal emphasized that appellate remedies cannot be defeated by procedural technicalities and restored the cases.

Reopening Dropped as Supreme Court Concession on AY 2015-16 Is Binding

January 6, 2026 642 Views 0 comment Print

The Tribunal held that reassessment notices issued after 1 April 2021 for AY 2015-16 are legally unsustainable. Since jurisdiction itself failed under TOLA principles, the entire reassessment was quashed.

Notice Issued for Incorrect Year Renders Reassessment Void

January 6, 2026 450 Views 0 comment Print

The reassessment was initiated for AY 2013-14 using reasons recorded for AY 2012-13. ITAT held that reopening for the wrong year is void, causing the entire Section 147 assessment to collapse.

Books Not Proper, Estimated Income Still Penalised by ITAT

January 6, 2026 444 Views 0 comment Print

ITAT Jaipur confirmed that Section 270A(6)(b) exclusion is inapplicable when accounts are incorrect or incomplete. Key takeaway: defective records make estimated disallowances liable to penalty.

CBDT Memorandum Not Conclusive Proof of Bogus Donation

January 6, 2026 444 Views 0 comment Print

The AO disallowed a weighted deduction relying only on a subsequent CBDT list. ITAT ruled that factual verification and proof of bogus donation are mandatory before denying the claim.

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