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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 282 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 657 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 291 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 58938 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


Section 271(1)(c) Penalty Fails When AO Accepts Reopened Return

January 24, 2026 606 Views 0 comment Print

The ruling clarifies that once a reassessment return is accepted, earlier returns lose relevance for penalty purposes. In the absence of defects in the reassessment return, penalty cannot survive.

Reassessment Notice & Order Quashed for Denial of Opportunity to Produce Accounts

January 24, 2026 1116 Views 0 comment Print

The issue was whether reassessment could proceed when financial statements were not called for despite the taxpayer’s willingness to furnish them. The court set aside the notice, holding that lack of proper opportunity vitiated the reopening.

Section 80HHC Amendment Non-Retrospective: Delhi HC Quashed Reassessment Notice

January 24, 2026 447 Views 0 comment Print

The Court held that reassessment based on a retrospective amendment to Section 80HHC is invalid. The key takeaway is that such amendments cannot reopen concluded assessments.

Income Tax Reassessment Notice Quashed for Breaching 10-Year Limitation Rule

January 24, 2026 630 Views 0 comment Print

The issue was whether a Section 148 notice for AY 2015-16 issued in August 2024 was time-barred. The Court held it exceeded the ten-year limit and quashed the proceedings.

Reassessment for AY 2015-16 Time-Barred After Rajeev Bansal Ruling: ITAT Kolkata

January 23, 2026 885 Views 0 comment Print

The issue was whether reassessment notices issued after the extended period under TOLA were valid. The Tribunal held that post–Rajeev Bansal, notices beyond the surviving limitation are time-barred and void.

No Section 271AAA Penalty Where Search Disclosure Was Proper: ITAT Kolkata

January 23, 2026 612 Views 0 comment Print

The issue was whether penalty could be levied despite disclosure of undisclosed income during search. The Tribunal held that when the assessee explains the manner of earning income and pays due tax, no penalty is leviable.

Penalty Deleted Where Income Already Disclosed & Additions Lead to Double Taxation

January 23, 2026 651 Views 0 comment Print

The Tribunal held that penalty cannot survive where sales were already offered to tax and later added again under section 68. The key takeaway is that double taxation cannot result in penalty when no tax was sought to be evaded.

Change of Opinion: ITAT Pune Quashes Reassessment; Section 68 & 40(a)(ia) Additions Fail

January 23, 2026 600 Views 0 comment Print

The issue was whether reassessment could be reopened on matters already examined in scrutiny. The Tribunal held that without fresh tangible material, reopening amounts to change of opinion and is invalid.

Notional JDA Income Not Taxable Without Real Accrual: ITAT Pune

January 23, 2026 489 Views 0 comment Print

The issue was whether notional income booked on a joint development agreement can be taxed before project commencement. The Tribunal held that only real income can be taxed and deleted the disallowance.

Reassessment Quashed for Failure to Dispose Objections Before Order: ITAT Mumbai

January 23, 2026 780 Views 0 comment Print

The issue was whether reassessment could survive when objections to reopening were ignored. The Tribunal ruled that non-disposal of objections violates mandatory procedure and renders the reassessment void ab initio.

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