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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 2829 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 294 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 699 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


Section 69C Not Attracted Where Expenses Are Recorded and Paid from Disclosed Sources

February 2, 2026 1359 Views 0 comment Print

Construction, fit-out, and IT installation costs capitalised in fixed assets were held genuine. The Tribunal emphasized substance of records over suspicion based on third-party allegations.

ITAT Delhi Quashed Reassessment which was Based Only on Audit Objection

February 2, 2026 591 Views 0 comment Print

The Tribunal held that reassessment initiated solely on the basis of an audit objection, without any independent application of mind, is invalid. Such reopening lacks the mandatory reason to believe and cannot sustain in law.

Bogus Purchase Theory Rejected; Section 69C Section 68 Additions Deleted in Full

February 2, 2026 903 Views 0 comment Print

Sales already offered to tax cannot be added again under section 68. With stock movement evidenced and books not rejected, treating recorded turnover as unexplained cash credit was held unsustainable.

Ad-hoc 20% Profit Estimate Set Aside; ITAT Restricts GP to 5% in Milk Trading Case

February 2, 2026 528 Views 0 comment Print

The Tribunal held that estimating profit at 20% of turnover in a milk trading business was arbitrary and unsupported by industry realities. It restricted the gross profit rate to 5%, recognising wastage, spoilage, and thin margins typical to the trade.

Jurisdiction for Reassessment Notices Clarified to End Faceless AO Disputes

February 2, 2026 3870 Views 0 comment Print

The Finance Bill, 2026 clarifies who can issue notices under sections 148 and 148A. It confirms that only jurisdictional Assessing Officers, not faceless units, can conduct pre-notice inquiries.

Section 80GGC Political Donation: Penalty Upheld despite Deduction Withdrawal After Reopening

February 1, 2026 6291 Views 0 comment Print

The Tribunal ruled that withdrawing a deduction in response to a Section 148 notice does not erase underreporting. Penalty for misrepresentation under Section 270A was upheld.

Reassessment for Bogus Purchases Quashed: Approval by Pr.CIT Invalid After 3 Years

January 31, 2026 903 Views 0 comment Print

ITAT Mumbai quashed reassessment for AY 2017-18 as notice issued after three years lacked mandatory sanction under Section 151(ii), holding approval by Pr.CIT insufficient under post-2021 law.

Section 153A Assessment Quashed as Notices Issued in Name of Deceased Assessee

January 31, 2026 408 Views 0 comment Print

The issue was whether an assessment could survive when statutory notices were issued in the name of a deceased person. The Tribunal held such notices invalid and quashed the entire assessment.

Addition quashed as Form 2 under Income Declaration Scheme not served: ITAT Chennai

January 31, 2026 399 Views 0 comment Print

ITAT Chennai held that section 197(b) of the Finance Act, 2016 cannot be invoked since Form 2 as contemplated under Income Declaration Scheme not served. Accordingly, addition u/s. 69A made in assessment u/s. 147 r.w.s. 144 liable to be deleted.

Reopening Beyond 3 Years Quashed for Want of Proper Section 151(ii) Sanction from Pr. CCIT

January 31, 2026 894 Views 0 comment Print

The Tribunal assessed compliance with revised reassessment provisions post Finance Act, 2021. It ruled that sanction by a lower authority after three years is non-est in law, leading to quashing of the reassessment.

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