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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


No Hearing, No Finality: ITAT Restores 69 Addition in Reassessment to AO

December 23, 2025 426 Views 0 comment Print

ITAT Bangalore directs reassessment with full hearing for an agriculturist after procedural lapses in notices and missed hearings. The ruling emphasizes the importance of fair opportunity under Sections 148 and 144B.

Provision of future expense allowed as deduction u/s. 37(1) based on matching principle of accountancy

December 23, 2025 906 Views 0 comment Print

ITAT Jaipur held that claim on account of provision of future expense is allowable under section 37(1) of the Income Tax Act as per matching principle of accountancy. Accordingly, appeal is allowed.

ITAT Bangalore: Section 148 Valid, Reassessment Set Aside for Non-Supply of Reasons

December 23, 2025 708 Views 0 comment Print

ITAT Bangalore invalidated a reassessment where the assessee was not provided the recorded reasons, emphasizing that reopening notices must be supported by clear, communicated reasons before filing returns.

Cash Deposits Alone Cannot Justify Reopening of Assessment: ITAT Delhi

December 23, 2025 924 Views 0 comment Print

The Tribunal struck down reopening where reasons conflicted and rested solely on AIR cash-deposit data. The key takeaway is that reassessment needs a clear, reasoned nexus.

SC Dismisses Reopening Challenge as Mere Change of Opinion Without Fresh Material

December 23, 2025 504 Views 0 comment Print

Supreme Court upheld the quashing of reassessment where scrutiny queries on deductions were earlier examined. It held that reopening based only on reappraisal of the same material amounts to an impermissible change of opinion.

Reassessment Notice Held Valid Because SCN Period Is Excluded from Limitation: ITAT Mumbai

December 22, 2025 666 Views 0 comment Print

The dispute centered on whether a reassessment notice was time-barred and sanctioned by the correct authority. The Tribunal held that the reply period under section 148A must be excluded, bringing the notice within three years and validating the sanction.

Section 144C Can’t Extend Limitation: TP Assessment Quashed as Time-Barred

December 22, 2025 486 Views 0 comment Print

The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.

No Forfeiture, No Tax: Advance Can’t Be Income Under Section 56

December 22, 2025 7017 Views 0 comment Print

The issue was whether advance money from a failed land deal could be taxed as income. The Tribunal held that without clear forfeiture, section 56(2)(ix) does not apply. Key takeaway: forfeiture is mandatory to tax advances.

ITAT Mumbai Quashed Reassessment Notice for Being Issued Beyond Limitation Period

December 22, 2025 858 Views 0 comment Print

The issue was whether a reassessment notice issued after the prescribed time limit was valid. The Tribunal held that notices for the relevant year issued after the cut-off date were barred by limitation, rendering the reassessment void.

Section 263 Revision Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission

December 22, 2025 204 Views 0 comment Print

The ITAT held that taxing only TDS credit, while leaving the underlying undisclosed commission untaxed, is a patent error. Section 263 revision was rightly invoked to protect revenue.

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