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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 14058 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 2823 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 1053 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

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 258 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 615 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 285 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 58935 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


ITAT Deletes Additions as Transactions Belonged to Separate Partnership Firms with Different PANs

June 23, 2026 147 Views 0 comment Print

ITAT Guwahati held that additions could not be sustained where the transactions related to a separate partnership firm with a different PAN and different partners. The Tribunal deleted the additions due to lack of evidence linking those transactions to the assessee.

Reassessment Quashed as AO Relied on Borrowed Satisfaction Without Independent Analysis

June 22, 2026 546 Views 0 comment Print

The ITAT Jaipur held that reassessment under Section 147 was invalid because the Assessing Officer merely relied on Investigation Wing information without independently analysing the material or establishing a nexus with the assessee.

Section 148 Notice Set Aside as AO Ignored Explanations & Supporting Materials

June 22, 2026 537 Views 0 comment Print

The Calcutta High Court set aside the Section 148A(3) order and Section 148 notice after finding that the Assessing Officer failed to consider the assessee’s detailed replies. The Court held that non-consideration of the replies violated the statutory requirement under Section 148A.

Pune ITAT Deletes ₹1.14 Crore Addition Based Solely on Hawala Operator’s Statement; Cross-Examination Denial Proves Fatal

June 22, 2026 252 Views 0 comment Print

The ITAT ruled that approval from the Principal Chief Commissioner/Chief Commissioner is mandatory for reopening assessments beyond three years. Since approval was obtained from an incorrect authority, the reassessment was declared void and the addition was deleted.

FMV of Surrendered Tenancy Rights Is Cost of Acquisition for Redeveloped Property: ITAT Mumbai

June 21, 2026 897 Views 0 comment Print

The Mumbai ITAT held that ownership premises received under a redevelopment scheme are acquired in exchange for valuable tenancy rights and cannot be treated as having a nil cost. It directed the Assessing Officer to adopt the fair market value of the surrendered tenancy rights for recomputing capital gains.

Reassessment Quashed as Section 143(2) Notice Was Issued Without Jurisdiction: ITAT Kolkata

June 21, 2026 630 Views 0 comment Print

The ITAT Kolkata held that the reassessment was invalid because the statutory notice under Section 143(2) was issued by an Assessing Officer lacking pecuniary jurisdiction. Having quashed the reassessment on jurisdictional grounds, the Tribunal did not examine the merits of the Section 68 addition.

Section 148 Notice quashed as Issuing Officer Had No Pecuniary Jurisdiction: ITAT Delhi

June 21, 2026 564 Views 0 comment Print

ITAT Delhi held that a reassessment initiated by an Assessing Officer without pecuniary jurisdiction under CBDT Instruction No. 1/2011 is invalid. The Tribunal quashed the reassessment and dismissed the Revenues appeal.

Reassessment Quashed as AO Failed to Decide Objections Before Assessment

June 21, 2026 333 Views 0 comment Print

The ITAT held that reassessment was invalid because the Assessing Officer did not dispose of the assessee’s objections through a separate speaking order before completing reassessment. The Tribunal quashed the reassessment following the principles laid down in GKN Driveshafts.

Reassessment Quashed as Third-Party Loose Papers Had No Live Link with Assessee: Gujarat HC

June 21, 2026 279 Views 0 comment Print

The Gujarat High Court held that reassessment under Section 148 cannot be based on third-party loose papers that fail to establish a live link with the assessee. The Court quashed the notice as the material was vague and unrelated to the petitioner’s transaction.

Gujarat HC Quashes Reassessment as Reopening Was Based on Unverified Complaint

June 21, 2026 465 Views 0 comment Print

The Gujarat High Court set aside the reassessment proceedings after holding that they were founded on an undated and uninvestigated complaint without any direct link to the petitioner. The Court found the reopening to be based on conjectures and surmises.

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