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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


No 143(2) Notice Means No Valid Assessment, Rules ITAT

December 30, 2025 600 Views 0 comment Print

The Tribunal held that an assessment completed without issuing notice under section 143(2) is void ab initio. Non-participation by the assessee cannot cure this jurisdictional defect.

Section 147 Reopening Can’t Be Based Only on Cash Deposit Alerts

December 30, 2025 489 Views 0 comment Print

The Tribunal quashed reassessment where the Assessing Officer invoked section 147 without examining books of account or correlating bank deposits with returned income.

Section 50C Not Applicable to Transfer of Life Interest in Property

December 30, 2025 873 Views 0 comment Print

The Tribunal held that assignment of a life interest under a trust does not amount to transfer of land or building. Since only a limited, determinable right was transferred, Section 50C could not be invoked.

Wrong Authority Approval Invalidates Reopening Beyond Three Years

December 30, 2025 528 Views 0 comment Print

The Tribunal ruled that where more than three years have elapsed, sanction must come from the Principal Chief Commissioner. Approval by the Principal Commissioner renders the reassessment void ab initio.

New Reassessment Law Overrides Old Limitation Extensions

December 30, 2025 681 Views 0 comment Print

The Tribunal held that a notice issued under section 148 on 31.07.2022 for AY 2014-15 was barred by limitation under the amended section 149. Reassessment proceedings were quashed as void ab initio.

Dumb Electronic Documents Cannot Create Taxable Investment

December 30, 2025 246 Views 0 comment Print

Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.

Faulty Chronology of Notices Vitiates Appellate Order

December 30, 2025 219 Views 0 comment Print

he tribunal held that an appellate order based on an incorrect and reconstructed timeline of statutory notices is unsustainable. Errors in sequencing of notices strike at the root of jurisdiction and require fresh adjudication.

Reopening Notice by JAO Invalid After Faceless Scheme

December 30, 2025 516 Views 0 comment Print

Applying a liberal approach, the tribunal condoned delay in appeal filing and examined the jurisdictional defect. Since reopening was initiated by the wrong authority, the assessment could not survive.

Digital Illiteracy Held Valid Ground to Condon Appeal Delay

December 30, 2025 402 Views 0 comment Print

The tribunal ruled that lack of digital literacy and non-receipt of electronic orders constitute sufficient cause for delay in filing an appeal. A liberal approach was adopted to ensure substantial justice, and the appeal was restored for decision on merits.

Section 148A and 148 Notices Quashed for Breach of Mandatory Faceless Procedure

December 30, 2025 729 Views 0 comment Print

he tribunal held that reassessment notices issued by the jurisdictional assessing officer instead of the faceless authority violate the mandatory faceless assessment framework. Such jurisdictional defects render the entire reassessment proceedings void ab initio.

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