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Section 148

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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 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


Section 148 Notice Held Premature While Return Filing Window Open

December 31, 2025 600 Views 0 comment Print

The issue was whether reassessment could be initiated while the time to file a belated return was still open. The Tribunal held such reopening premature and void, as income cannot be said to have escaped assessment.

Borrowed Satisfaction Backfires: ITAT Ahmedabad Quashes 147 Reopenings Based on Dishman Group Search Inputs

December 31, 2025 693 Views 0 comment Print

ITAT held reassessment invalid as it was initiated merely on Insight Portal data and third-party statements without verification or application of mind.

JAO Can’t Reopen After Faceless Regime: ITAT Hyderabad Quashes s.148 Notices in 4 Appeals

December 31, 2025 450 Views 0 comment Print

The ITAT held that reassessment notices issued by a JAO after 29.03.2022 are void, as only a Faceless Assessing Officer can act under the faceless regime.

Reassessment Quashed for Non-Service of Notice: ITAT Delhi Strikes Down Jurisdictional Lapse

December 30, 2025 408 Views 0 comment Print

The issue was whether reassessment could survive when the mandatory section 148 no-tice was sent to an old address. The Tribunal held that improper service vitiates jurisdiction, rendering the entire reassessment void.

Reopening Collapses, All Other Additions Fall: ITAT Delhi Dismisses Revenue’s Appeal

December 30, 2025 465 Views 0 comment Print

The issue was whether additions could survive when the sole reason for reopening was not challenged. The ITAT held that without a valid reopening foundation, no other additions are sustainable.

CSR Grants Are Tied-Up Funds, Not Free Income of Charitable Trust

December 30, 2025 477 Views 0 comment Print

The Tribunal held that CSR contributions received with strict donor directions and refund obligations may constitute tied-up grants rather than freely available income. Such funds require factual examination before taxing them under section 11.

Past U/s 80-IA Relief Doesn’t Guarantee Deduction for New Projects

December 30, 2025 309 Views 0 comment Print

The Tribunal held that deduction under section 80-IA cannot be allowed mechanically based on past relief. Each infrastructure project must be independently examined to determine whether it qualifies as development or is merely a works contract.

Section 153C Notice Invalid for 22-Month Delay in Recording Satisfaction

December 30, 2025 573 Views 0 comment Print

The Tribunal reaffirmed that satisfaction must be recorded contemporaneously or immediately after the searched person’s assessment. Any belated recording invalidates the assumption of jurisdiction under section 153C.

Reassessment dropped as tax paid on consolidated profit and hence no escapement of income

December 30, 2025 615 Views 0 comment Print

ITAT Rajkot held that there is no escapement of income or loss of revenue since tax paid on the basis of consolidated profit of both the partnership firm and hence reassessment proceedings are not sustainable. Accordingly, appeal of revenue is dismissed.

Employee Not Liable for Employer’s Business Expenses

December 30, 2025 270 Views 0 comment Print

The Tribunal deleted additions holding that expenses incurred on behalf of an employer company and recorded in its books cannot be assessed in the employee’s personal assessment.

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