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Section 148

Latest Articles


A comprehensive analysis of function of electronic information in tax assessments

Income Tax : Explore how electronic data transforms tax assessments, highlighting accuracy issues, verification needs, and taxpayer rights as s...

August 7, 2024 873 Views 0 comment Print

Note on Income Tax Notices Issued: Section148 read with Section 135A

Income Tax : Learn about the revised procedure for reopening cases under Section 148 RWS 135A and the implications of Finance Act 2021, includi...

July 31, 2024 2634 Views 0 comment Print

Budget 2024: Rationalization of Income Tax Re-assessment Provisions

Income Tax : Discover the key amendments in the Finance (No.2) Bill, 2024, affecting income tax reassessment procedures under the Income-tax Ac...

July 25, 2024 1164 Views 0 comment Print

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 1005 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 1629 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 546 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 1080 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 6483 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 6954 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 12915 Views 0 comment Print


Latest Judiciary


Passing of order u/s. 148A(d) on the basis of fresh ground untenable: Delhi HC

Income Tax : Delhi High Court held that passing of order by the revenue under section 148A(d) of the Income Tax Act on the basis of fresh groun...

August 17, 2024 195 Views 0 comment Print

Addition u/s. 68 justified as genuineness of transaction and creditworthiness of creditors not proved: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that genuineness of transaction, creditworthiness and identity of creditors not proved, hence addition u/s. 68...

August 17, 2024 102 Views 0 comment Print

Advance tax payment provisions doesn’t apply in reassessment proceedings: ITAT Indore

Income Tax : ITAT Indore held that rejection of appeal by CIT(A) on the footing of non-payment of advance tax as required by section 249(4)(b) ...

August 17, 2024 90 Views 0 comment Print

Notice u/s. 148 to NRI without following mandatory faceless procedure unsustainable: Telangana HC

Income Tax : Telangana High Court held that notice issued u/s. 148 of the Income Tax Act must comply with the requirement of the Scheme whether...

August 17, 2024 447 Views 0 comment Print

Notice u/s. 148A issued by Jurisdictional AO instead of Faceless AO liable to be quashed: Bombay HC

Income Tax : Bombay High Court held that issuance of notice under section 148A of the Income Tax Act by Jurisdictional Assessing Officer and no...

August 17, 2024 762 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 15774 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 3288 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 5376 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 2952 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 13533 Views 0 comment Print


Other addition in reassessment proceedings not sustainable if Foundational Additions are deleted 

June 1, 2022 1338 Views 0 comment Print

Assessing Officer can make `other addition’ in the reassessment proceedings, provided, the `foundational addition’ is made. When this proposition is taken to a next level, no different consequences will emerge, if the `foundational addition’ is itself finally deleted in an appeal.

Is CBDT instruction on issue of section 148 notice legally incorrect?

May 30, 2022 40047 Views 10 comments Print

An analysis of the legal correctness of CBDT Instruction No. 01/2022 and its implications on section 148 notices under the Income Tax Act.

HC directs govt to take action against officers erring in passing Assessment Order

May 30, 2022 2523 Views 0 comment Print

Harish Chandra Bhati Vs PCIT (Allahabad High Court) Personal Affidavit of Shri Tarun Bajaj, Revenue Secretary to The Govt. of India has been taken on record. It provides for initiation of suitable administration action against the erring officer where assessments are found to be high pitched or there is non-observence of Principles of natural justice, […]

HC directs proceeding against officers passing erroneous order

May 29, 2022 4293 Views 0 comment Print

Dharmendra Kumar Singh Vs Union of India (Allahabad High Court) Instruction F. No. 225/101/2021/-ITA-II, dt. 25/04/22 provides for initiation of suitable administrative action against the erring officer in case where assessments are found by the local committee to be high-pitched or where there is non-observance of principles of natural justice, non- application of mind or […]

The Reopening Labyrinth – Section 148 – Income Tax Act

May 26, 2022 14079 Views 0 comment Print

Apex Court in its recent judgment put quietus to one of the largely litigated issue on validity of notices issued under section 148 of Income Tax Act between the period 01.04.2021 to 30.06.2021.

Reassessment notice dealing with question of facts, can’t be challenged before HC

May 26, 2022 1656 Views 0 comment Print

Reassessment notice under Section 148 of IT Act i.e, impugned notice if carried to its logical end, in the facts and circumstances of the case, will clearly neutralize all these arguments and the writ petitioner assessee bank will not be aggrieved in any manner.

Fresh Reassessment Pending conclusion of first reassessment proceedings is invalid

May 25, 2022 1308 Views 0 comment Print

Shri Jaideep Singh Vs ITO (ITAT Jaipur) A question that arises for con sideration is whether the AO can issue second notice u/s 148 and initiate fresh reassessment proceedings before completion/conclusion of proceedings initiated by way of first notice u/s 148 either by way of dropping the first reassessment proceedings or completing the proceedings by […]

Initiation of reassessment, based on wrong assumption of facts, is bad in law

May 24, 2022 1614 Views 0 comment Print

Reopening is on the wrong assumption of facts and the information received from another assessing officer would not by itself be the basis to have a belief that the income has escaped assessment. Accordingly, we find the reassessment is bad in law and quash the assessment order passed u/s 143(3) r.w.s 147 of the Act.

Availability of tangible material is pre-conditional for reopening of assessment

May 24, 2022 954 Views 0 comment Print

Valco Industries Ltd Vs ACIT (ITAT Chandigarh) Facts- The assessee originally filed return declaring total income of Rs.4,83,83,620/- on 28.09.2012 after claiming deduction of Rs.5,75,64,789/- u/s 80IC of the Act. The assessment was completed u/s 143(3) of the Act on 27.03.2015 at an income of Rs.8,07,03,620/- after making an addition of Rs.3,23,20,000/- on account of […]

No bar under law to initiate fresh reassessment proceedings

May 23, 2022 702 Views 0 comment Print

Shivsamarth Group Vs PCIT (ITAT Pune) Admittedly, in the present case, the order which is sought to be revised is the order dropping the reassessment proceedings u/s 147 of the Act. On carefully going through the material on record, it would be clear that the original reassessment proceedings were initiated with view to tax the […]

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