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Section 148

Latest Articles


Bombay HC Invalidates Reassessment Notice for AY 2015-16: Lack of DIN & Jurisdictional Issue

Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...

July 6, 2024 834 Views 0 comment Print

Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Wrong SFT Reporting may invite Notice U/s 148A of Income Tax Act, 1961

Income Tax : Discover the consequences of incorrect SFT reporting triggering U/s 148A notices under the Income Tax Act, 1961. Learn from a deta...

February 27, 2024 3453 Views 0 comment Print

Proposed Penal Provision For Non Registration of Machines In GST

Goods and Services Tax : Explore the proposed penalties in Finance Bill 2024 for non-registration of machines under GST. Analysis of Section 122A and the i...

February 13, 2024 5004 Views 0 comment Print


Latest News


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 6453 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 6936 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 12900 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 41382 Views 2 comments Print

Recall section 148 issued notice under old law after 31.03.2021

Income Tax : DTPA has made a representation to Finance Minister, Smt. Nirmala Sitharaman and requested for for recalling notices under section...

July 5, 2021 21189 Views 3 comments Print


Latest Judiciary


Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 66 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 126 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 261 Views 0 comment Print

Non-Filing of GST Return by Supplier – Assessment Reopening Validity- ITAT Mumbai Order

Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...

July 17, 2024 744 Views 0 comment Print

Section 153A: No Additions Without Incriminating Material for Completed Assessments

Income Tax : Delhi High Court dismisses Income Tax Department's appeal in PCIT Vs Satya Prakash Gupta case, finding no evidence of commission r...

July 16, 2024 207 Views 0 comment Print


Latest Notifications


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 12375 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 3063 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 5337 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 2934 Views 0 comment Print

Carry out due verification before initiating Section 148/147 proceedings: CBDT

Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...

August 22, 2022 13356 Views 0 comment Print


No addition for mere registration of property in Assessees name without actual transfer of money

July 10, 2022 1503 Views 0 comment Print

Adilakshmi Srungavarapu Vs ITO (ITAT Visakhapatnam) Admitted facts are that the husband of the assessee in order to retain the property got the property registered in the assessee’s name and has repaid the loans borrowed by him by sale of gold jewellery and personal savings of the assessee. We also find merit in the argument […]

Reassessment Proceedings cannot be initiated against a dead person

July 10, 2022 963 Views 0 comment Print

Ela Roy Vs ITO (Calcutta High Court) Petitioner being the sister of the noticee, in response to notice under Section 148 of the Act has filed the return. Petitioner submits that she being a lay person, due to inadvertence has filed the return on behalf of her brother noticee though she had already informed the […]

Mere digitally signing of Section 148 notice cannot be regarded as issuance of notice

July 9, 2022 8052 Views 0 comment Print

Understand the significance of digitally signing a notice under section 148 of the Income-tax Act. Learn why it cannot be considered as the issuance of notice according to the Allahabad High Court.

Creditworthiness of Lender not proved: Section 148A(d) order valid

July 7, 2022 855 Views 0 comment Print

Indus Technical Education Society Vs Union of India (Allahabad High Court) So far as unsecured loan of Rs. 28,53,439/ is concerned, the petitioner could not submit any credible evidence alongwith its reply to establish credit worthiness of the lender i.e. M/s Arrow Netmart Pvt. Ltd. Therefore, prima facie, the Assessing Authority had some relevant material […]

How to deal with Section 148 & Section 148A Income Tax Notices

July 6, 2022 229545 Views 11 comments Print

Unravel the complexities of Section 148 & Section 148A Income Tax notices. Learn how to effectively handle these notices and protect your financial interests.

IBC proceedings cannot dilute rights of Income Tax Depat to reopen assessment

July 2, 2022 12027 Views 0 comment Print

The Madras High Court rules that IBC proceedings cannot affect the rights of the Income Tax Department to reopen assessments.

Section 148 Negotiable Instrument Act order were interlocutory in nature & not revisable

June 30, 2022 2763 Views 0 comment Print

Order for grant of suspension of sentence or bail were all interlocutory orders and were not revisable under Section 397 of the Code of Criminal Procedure.

Reassessment without Service of Section 148 Notice is void ab initio

June 30, 2022 3300 Views 0 comment Print

Naveen Tyagi Vs ITO (ITAT Delhi) HC held that if notice u/s 148 was not served on the assessee in accordance with law the reassessment made consequent thereto was without jurisdiction and liable to be quashed. In the case on hand as the Revenue could not prove the service of notice u/s 148 on the […]

Validity of Satisfaction to reopen Assessment recorded with one word “Yes”

June 30, 2022 870 Views 0 comment Print

Kedar Cotton Industries Vs DCIT (ITAT Ahmedabad) It is observed that the approval to reopen the assessment in the present case and issue notice under Section 148 of the Act to the assessee was accorded by the learned Principal Commissioner of Income-tax by recording his satisfaction in one word ‘Yes‘ and even the learned DR […]

Additions in Reassessment Proceedings not Sustainable If no Addition on Primary Grounds

June 30, 2022 3732 Views 0 comment Print

Honble Delhi High Court considering the decision of the Honble Bombay High Court in the case of CIT Vs. M/s. Jet Airways (I) Limited (2011) 331 ITR 236 (Bom.) held that if the Assessing Officer does not make any addition on the primary ground on the basis of which proceedings under Section 147 were initiated he cannot make other additions.

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