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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


ITAT Visakhapatnam Quashed Reassessment as Notice Was Issued by Wrong Authority

January 6, 2026 597 Views 0 comment Print

Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]

PF/ESI Due Date Verification Incomplete, Matter Sent Back to AO

January 6, 2026 267 Views 0 comment Print

The issue centered on employees’ PF contributions and statutory due dates post-Checkmate ruling. The ITAT held that detailed verification was still required, warranting remand.

Notice Issued Via ITBA After 01-04-2021 Triggers New Reopening Law

January 6, 2026 525 Views 0 comment Print

The issue was whether a notice dated 31-03-2021 but digitally signed on 01-04-2021 was valid. The ITAT held the notice was issued under the new regime without following section 148A, rendering reassessment void.

AY 2015-16 Reassessment Void as Post-2021 Notices Are Time-Barred

January 6, 2026 600 Views 0 comment Print

The AO added ₹1 crore based on alleged cash receipts from third-party material. The Tribunal held the reopening itself was invalid, so the addition could not survive.

Section 148 Notices for AY 2015-16 Invalid Under New Regime

January 6, 2026 1299 Views 0 comment Print

The AO issued reassessment notices during the post-Ashish Agrawal transition phase. Applying later Supreme Court law, the ITAT held AY 2015-16 is beyond the permissible reopening period.

Cash Deposits Added as Unexplained Income Because Sales Bills Were Not Examined

January 6, 2026 669 Views 0 comment Print

The tribunal held that where key sales and purchase documents were not examined at assessment, the issue must be remanded. Cash deposit additions were set aside for fresh verification by the Assessing Officer.

No Proof of On-Money, ₹1.52 Cr Buyer Addition Deleted

January 6, 2026 387 Views 0 comment Print

No incriminating material showed payment over the registered consideration. The tribunal held that without independent evidence, the ₹1.52 Cr addition could not be sustained.

Post-2022 Reassessment Fails for Ignoring Faceless Procedure

January 6, 2026 831 Views 0 comment Print

The case examined whether reassessment proceedings could survive when issued outside the faceless mechanism. The ruling confirms that non-compliance with the faceless scheme is a fatal jurisdictional defect.

ITAT Mumbai Condoned 182-Day Delay as Substantial Justice Prevails Over Limitation

January 6, 2026 459 Views 0 comment Print

The Tribunal held that a bona fide delay caused by genuine circumstances deserves condonation. The key takeaway is that technical limitation cannot override substantive justice.

Reassessment Quashed Because Section 148 Notice Was Time-Barred

January 5, 2026 999 Views 0 comment Print

The issue was whether a reassessment notice issued in July 2022 for AY 2015-16 was valid. The Tribunal held it to be barred by limitation, rendering the entire reassessment void.

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