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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 108 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


PCIT Can’t Convert Bogus Purchases Into U/s 69C to Apply U/s 115BBE

December 27, 2025 1014 Views 0 comment Print

The issue was whether bogus purchases disallowed under section 37(1) must be reclassified as unexplained expenditure under section 69C. ITAT held that where the source of expenditure is known, section 69C cannot be mechanically invoked.

AIR-Based Reopening Sends NRI Investment Case Back to AO

December 27, 2025 477 Views 0 comment Print

The Tribunal held that AIR-triggered reopening and additions cannot stand where an NRI explains investments with foreign remittance evidence, and remanded the case for fresh verification.

Bogus Commission to Shell Entity Taxable Under Section 68

December 27, 2025 354 Views 0 comment Print

The Tribunal held that commission paid to a shell concern with no real services is taxable as unexplained credit. Claims that expenditure related to an earlier year were rejected.

Order of Competent Authority granting or refusing sanction u/s. 151 is not appealable order

December 27, 2025 480 Views 0 comment Print

Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.

Section 148A Proceedings Cannot Cure Invalid Old Reassessment Notice

December 27, 2025 1062 Views 0 comment Print

The Tribunal ruled that once the original notice itself is jurisdictionally invalid, later compliance with section 148A is irrelevant. Foundational defects cannot be remedied procedurally.

Bogus Purchases Don’t Justify 100% Addition When Sales Are Accepted

December 27, 2025 558 Views 0 comment Print

The Tribunal held that when sales are not disputed, the entire value of alleged bogus purchases cannot be added under section 69C. Only the embedded profit element is taxable.

Survey-Based Suspicion Not Enough: AMP & Credit-Note Payments Allowed by ITAT

December 27, 2025 279 Views 0 comment Print

The Tribunal ruled that AMP expenses incurred by a brand-owning trader cannot be allocated to contract manufacturers without proof of obligation or agreement. Tax incentives enjoyed by related entities alone were held insufficient.

Faceless Reassessment Is Mandatory: Chennai ITAT Sets Aside 69A Addition Despite Cash Deposits

December 26, 2025 2724 Views 0 comment Print

The Tribunal held that reassessment initiated by a jurisdictional officer after the faceless scheme became mandatory was invalid. The key takeaway is that failure to follow the faceless mechanism nullifies the entire reopening, regardless of merits.

Mechanical Dismissal Fails as CIT(A) Skips Speaking Order

December 26, 2025 558 Views 0 comment Print

ITAT held that dismissing a ground without reasons violates appellate duty. The 43B disallowance was remanded for fresh, reasoned adjudication.

Bombay HC Quashed Reopening After Four Years Due to Change of Opinion

December 26, 2025 552 Views 0 comment Print

The judgment reiterates that reassessment cannot be initiated merely because the AO takes a different view later. Jurisdictional limits under tax law were strictly enforced.

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