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Section 148

Latest Articles


Bombay HC Invalidates Reassessment Notice for AY 2015-16: Lack of DIN & Jurisdictional Issue

Income Tax : Explore the Bombay High Court's ruling on the invalidity of a reassessment notice under Section 148 of the Income-tax Act, 1961, f...

July 6, 2024 834 Views 0 comment Print

Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Wrong SFT Reporting may invite Notice U/s 148A of Income Tax Act, 1961

Income Tax : Discover the consequences of incorrect SFT reporting triggering U/s 148A notices under the Income Tax Act, 1961. Learn from a deta...

February 27, 2024 3453 Views 0 comment Print

Proposed Penal Provision For Non Registration of Machines In GST

Goods and Services Tax : Explore the proposed penalties in Finance Bill 2024 for non-registration of machines under GST. Analysis of Section 122A and the i...

February 13, 2024 5004 Views 0 comment Print


Latest News


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 6453 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 6936 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 12900 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 41382 Views 2 comments Print

Recall section 148 issued notice under old law after 31.03.2021

Income Tax : DTPA has made a representation to Finance Minister, Smt. Nirmala Sitharaman and requested for for recalling notices under section...

July 5, 2021 21189 Views 3 comments Print


Latest Judiciary


ITAT Upholds Section 56(2) Addition for Property Purchase Without Consideration

Income Tax : Read the detailed analysis of Indira Ramaiah Vs ITO case by ITAT Bangalore. ITAT upheld the addition of gift for undisclosed inves...

July 18, 2024 42 Views 0 comment Print

Assessment Order Passed after allowing only 2 Days to respond to SCN not Sustainable

Income Tax : In this case, Gudiyatham Muniraj Ashokkumaran challenged an assessment order, citing breach of natural justice principles due to i...

July 18, 2024 36 Views 0 comment Print

Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 72 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 132 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 273 Views 0 comment Print


Latest Notifications


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 12387 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 3066 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 5337 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 2934 Views 0 comment Print

Carry out due verification before initiating Section 148/147 proceedings: CBDT

Income Tax : Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs i...

August 22, 2022 13359 Views 0 comment Print


For initiation of Section 147 proceedings AO has to consider prima facie material not sufficiency of correctness of material

May 10, 2022 654 Views 0 comment Print

At the time of initiating the proceedings under Section 147 of the Act, the assessing officer has to only examine whether there is prima facie material on the basis of which the assessment should have been reopened. The Supreme court has held that at this stage the court is only required to see whether there was prima facie some material on the basis of which the department could reopen the case. The sufficiency of the correctness of the material is not a thing to be considered at the stage.

Income Taxpayers Will Face the Heat of Reassessment!

May 10, 2022 15639 Views 0 comment Print

Arjuna, there is too much discussion going on regarding the validity of notices issued between 01-04-2021 and 30­06-2021 u/s 148 of the Income Tax Act for reassessment proceedings. The income tax department had issued notices u/s 148 for reassessment proceedings.

Landmark SC Judgment on Section 148 notices which is in Favour of both Assessee & Revenue

May 9, 2022 27609 Views 3 comments Print

Landmark Supreme Court judgment on section 148 notices in favor of both Assessee and Revenue. Key takeaways for taxpayers and Income Tax Department.

Reopening for Mere High Turnover in bank account not justified

May 9, 2022 771 Views 0 comment Print

Merely that there were huge turnover i.e. deposits and withdrawal in the bank account of the assessee without correlating the same with the accounts and with the nature of the business of the assessee, in our view, that was not enough to form a belief of escapement of income of the assessee for the assessment year under consideration.

Change of opinion not constitutes justification for Reopening

May 9, 2022 321 Views 0 comment Print

Lokhandwala Construction Industries Private Limited Vs DCIT (Bombay High Court) In this case, during the original assessment proceedings, a notice dated 19th October 2019 was issued under Section 142(1) of the Act by which petitioner was called upon to furnish copies of Index II(s) of three flats sold during the year. Petitioner responded by its […]

In case of violation of principles of natural justice, the availability of appellate remedy does not bar maintainability of writ petition

May 8, 2022 1716 Views 0 comment Print

When there is a violation of the principles of natural justice, the availability of an appellate remedy does not bar the maintainability of a writ petition.

SC Judgment on Section 148 Notices – Using Missile where Rifle could have sufficed

May 8, 2022 3012 Views 0 comment Print

Analysis of the recent Supreme Court judgment on Section 148 Notices. Find out if the court used excessive force when a simpler approach would have sufficed.

Way ahead in reassessment after Supreme Court decision

May 8, 2022 6468 Views 0 comment Print

Understanding the Supreme Court’s decision on reassessment after the amendment. Learn about the rights of the Revenue and Assessees in this legal controversy.

Reincarnation of Section 148 Reassessments Notices issued post 01/04/2021

May 8, 2022 12336 Views 0 comment Print

Learn about the impact of the Finance Act 2021 on reassessment notices and the validity of unamended Act notices issued post 01/04/2021.

Section148 Notices not become invalid merely for issue under old law: SC

May 7, 2022 3825 Views 0 comment Print

SC rules that Section148 Notices issued under old law remain valid. Taxpayers cannot use change in law as an excuse to escape proceedings.

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