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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 105 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 189 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


No Automatic Addition Based on Form 26AS Mismatch if No Matching Bank Credits

May 12, 2026 252 Views 0 comment Print

The assessee claimed that amounts deposited in bank accounts were retailer collections remitted to the telecom company and not commission income. The Tribunal directed the Assessing Officer to conduct proper verification.

Ex Parte Assessment on Bitcoin Transactions Sent Back for Fresh Hearing: ITAT Delhi

May 12, 2026 153 Views 0 comment Print

ITAT Delhi condoned a 333-day delay in filing appeal after finding the reasons stated by the assessee to be bona fide. The matter was remanded to the CIT(A) for fresh consideration.

No Incriminating Material, No 153A Addition: ITAT Bangalore Deletes Massive Additions in JDA Search Case

May 12, 2026 306 Views 0 comment Print

ITAT Bangalore held that Section 45(5A) applies prospectively and cannot govern JDAs executed before 01.04.2018. Capital gains from older development agreements must be taxed under the law applicable in the year of transfer.

Reassessment Invalid Where Seized Document Did Not Match Agricultural Land Sale: Gujarat HC

May 11, 2026 204 Views 0 comment Print

The Gujarat High Court quashed reassessment proceedings after finding that the seized loose paper referred to non-agricultural land rates recorded after the petitioner had already sold agricultural land. The Court held that reopening based on hypothetical assumptions and unrelated material was unsustainable.

Escaped Income Below ₹50 Lakh? Reopening After 3 Years Is Dead on Arrival: ITAT Quashes NRI Reassessment

May 11, 2026 174 Views 0 comment Print

The Mumbai ITAT held that reassessment under Section 148 cannot be initiated after three years unless the alleged escaped income exceeds ₹50 lakh. Since the disputed amount was only ₹7.10 lakh, the reopening was quashed.

Software Licences Aren’t Capital Assets: ITAT Allows ₹37.87 Crore Deduction to BNP Paribas

May 11, 2026 147 Views 0 comment Print

The Mumbai ITAT held that expenditure on software licences, maintenance, database access and periodic upgrades is allowable as revenue expenditure. The Tribunal ruled that mere use of software does not create a capital asset or enduring ownership right.

AO’s Own Penalty Order Sinks Reassessment: ITAT Holds First Section 147 Order ‘Infructuous’

May 11, 2026 141 Views 0 comment Print

The Tribunal ruled that the Income Tax Department cannot pass two reassessment orders for the same assessment year, same transaction, and same addition. The first reassessment proceedings were held legally unsustainable.

SEZ Lease Rentals Are Business Income, Not House Property: ITAT Mumbai

May 11, 2026 168 Views 0 comment Print

The Mumbai ITAT reaffirmed that lease rentals from SEZ and IT Parks along with amenities are taxable as business income. The ruling relied on CBDT Circular No. 16/2017 and multiple judicial precedents supporting taxpayers.

Reassessment Notice Quashed as Fresh Section 148 Notice Was Time-Barred: ITAT Delhi

May 9, 2026 282 Views 0 comment Print

The ITAT Delhi held that reassessment notices issued after expiry of the surviving limitation period under the amended reassessment regime were invalid. The Tribunal quashed the reopening proceedings and related penalties for both assessment years.

Entire Bank Deposits Cannot Be Taxed as Income – ITAT Restricts Addition to 2% in Renukamata Society Cases

May 9, 2026 1335 Views 0 comment Print

The Pune ITAT held that entire cash deposits in bank accounts cannot automatically be treated as unexplained income when the assessee appears to be only a conduit in an accommodation entry network. The Tribunal restricted the taxable addition to 2% of deposits after finding no evidence of actual enrichment.

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