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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 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


Reassessment u/s. 147 after expiry of four years tenable since all material facts not disclosed

December 23, 2025 393 Views 0 comment Print

Madras High Court held that reassessment under section 147 of the Income Tax Act after expiry of four years is sustainable in law since assessee has failed to set out truly and fully all the material facts.

Wrong Authority Approval Voids Reassessment Beyond 3 Years

December 23, 2025 684 Views 0 comment Print

The Tribunal held that approval by an incompetent authority under Section 151(ii) invalidates a reassessment issued after three years. The notice and consequential order were declared void for lack of jurisdiction.

Fair Hearing Mandatory for Section 251 Income Enhancement: ITAT Amritsar

December 23, 2025 276 Views 0 comment Print

ITAT ruled that enhancement of income under section 251 without giving the assessee a proper hearing is invalid. The appeals were remanded to CIT(A) for fresh adjudication.

Belated U/s 148 Return Costs Assessee: 1% NP Estimation Upheld

December 23, 2025 216 Views 0 comment Print

The tribunal held that non-filing of return within the due date disentitled the assessee from deduction under section 80P due to section 80AC. Consequently, lower profit claims based on accounts were rejected.

Agent Collections vs Own Sales—Hyderabad ITAT Remands 69A Addition for Fresh Verification

December 23, 2025 348 Views 0 comment Print

The tribunal observed that Way Bills produced by the assessee prima facie supported the claim of business sales. The addition was therefore set aside and restored for fresh verification.

Section 69A Addition of ₹1.86 Cr Set Aside for Lack of Verification of College Fee Collections

December 23, 2025 519 Views 0 comment Print

The ITAT set aside a ₹1.86 crore addition under section 69A for unexplained deposits, noting the deposits were likely student fees. The ruling emphasizes the need to verify exempt income before making tax additions.

Entire Share Sale Proceeds Can’t Be Taxed as Capital Gains: ITAT Visakhapatnam

December 23, 2025 348 Views 0 comment Print

The ITAT held that equity share purchases routed through the disclosed bank account cannot be treated as unexplained without proper verification. The AO was directed to provide transaction details and re-examine the source to avoid double additions.

Cash Labour Payments Cannot Be Disallowed on Guesswork: ITAT Pune

December 23, 2025 273 Views 0 comment Print

The Tribunal observed that rejection of audited books and disallowance of labour charges must be backed by concrete defects. Purely ad-hoc estimations based on minimum wages were held improper.

No Concurrent Jurisdiction Between FAO and JAO Under Reassessment Law: ITAT Visakhapatnam

December 23, 2025 765 Views 0 comment Print

The Tribunal found that notices issued manually by the jurisdictional officer contravene the faceless reassessment framework. There is no concurrent jurisdiction between faceless and jurisdictional officers. Any reassessment initiated this way is invalid from inception.

Reassessment Fails When Jurisdictional Officer Issues Section 148 Notice

December 23, 2025 2493 Views 0 comment Print

The Tribunal held that after 29-03-2022, only a Faceless Assessing Officer is empowered to issue notices under Section 148. Notices issued by a jurisdictional officer were declared void, vitiating the entire reassessment.

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