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Section 148A

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 399 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

Reassessment Notice Quashed Because Section 148 Action Exceeded Surviving Limitation After SC Framework

Income Tax : The High Court held that reassessment proceedings for AY 2013-14 were time-barred after computing the surviving limitation as clar...

March 5, 2026 1092 Views 0 comment Print

Retrospective Amendments under Budget 2026 – Rectification, Revision, Reassessment Options before Tax Authorities

Income Tax : Budget 2026 introduces sweeping retrospective amendments affecting limitation, reassessment jurisdiction, DIN validity, and TPO ti...

February 26, 2026 6219 Views 1 comment Print

Section 148A: When Formality Becomes a Opportunity

Income Tax : The new reassessment framework mandates enquiry, hearing, and a reasoned order before reopening. Courts now test jurisdiction on p...

February 10, 2026 942 Views 0 comment Print


Latest News


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 4398 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 6879 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

IT officers association demand extension of Time Barring Date for assessment

Corporate Law : Non- extension of the Time Barring Date for assessment of reopened cases and issuance of the notices for reopening – difficu...

March 29, 2022 8679 Views 0 comment Print


Latest Judiciary


DVO Valuation Alone Cannot Justify Section 69 Addition Without Extra Payment Proof: ITAT Amritsar

Income Tax : The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra paymen...

May 22, 2026 93 Views 0 comment Print

Reopening Quashed as It Was Based on Unverified PDF Complaint Found on Third Party’s Mobile Phone: Gujarat HC

Income Tax : The Court held that the petitioner had no connection with the entities or individuals from whose devices the disputed material was...

May 22, 2026 105 Views 0 comment Print

Assessment Order Quashed Due to Email Communication Issue Despite Valid Section 148 Notice

Income Tax : Court upheld the validity of the Section 148 notice but set aside the assessment order after finding that notices were sent to an ...

May 22, 2026 321 Views 0 comment Print

Opening Balances Cannot Be Added Under Section 68 as They Relate to Earlier Years

Income Tax : Tribunal reiterated that credits brought forward from earlier financial years cannot ordinarily be taxed under Section 68 in subse...

May 22, 2026 210 Views 0 comment Print

Delhi HC Quashes Reassessment as Income Tax Department Changed Grounds Midway

Income Tax : The Delhi High Court held that reassessment proceedings cannot be sustained on changing allegations introduced after issuance of n...

May 21, 2026 201 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

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 5907 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 3372 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 16011 Views 1 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 15384 Views 0 comment Print


Ex-Parte Appeal Dismissal Set Aside for Lack of Reasoned Order

January 16, 2026 351 Views 0 comment Print

The issue was whether the appellate authority could dismiss an appeal ex-parte without giving detailed reasons. The Tribunal held that a non-speaking order violates section 250(6) and restored the appeal for fresh adjudication.

Reassessment Quashed as JAO Lacked Jurisdiction After Faceless Scheme

January 16, 2026 1932 Views 0 comment Print

The issue was whether reassessment notices could be issued by a jurisdictional officer after the faceless reassessment scheme became mandatory. The Tribunal held that such notices are void, rendering the entire reassessment unsustainable.

Reassessment Quashed for Issuance of Notice Outside Faceless Regime

January 16, 2026 1809 Views 0 comment Print

The issue was whether reassessment could be initiated by a jurisdictional officer after faceless schemes became mandatory. The Tribunal held that notices issued outside the faceless mechanism lack jurisdiction and invalidate the reassessment.

CIT(A) Cannot Set Aside Case After Favorable Remand Report: ITAT Delhi

January 15, 2026 393 Views 0 comment Print

The Tribunal ruled that setting aside a best-judgment assessment after admitting additional evidence and remand findings is unjustified. CIT(A) must decide the case conclusively instead of granting a fresh lease to the AO.

Borrowed Satisfaction from Investigation Wing Not Permissible

January 15, 2026 1218 Views 0 comment Print

The Tribunal ruled that reassessment based on borrowed satisfaction, without inquiry or verification by the AO, is unsustainable. Independent application of mind is mandatory under the new regime.

Section 148 Notice Issued Beyond Surviving Time Invalid: ITAT Delhi

January 15, 2026 1080 Views 0 comment Print

The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.

Share Certificate Transfer Dates Prove Holding Period; ITAT Allows LTCG Despite Purchase Date Doubts

January 15, 2026 378 Views 0 comment Print

Purchase Date Doubts Not Enough to Deny LTCG Exemption: ITAT Mumbai held that transfer dates shown in share certificates satisfied the statutory holding requirement.

Section 147 Reassessment Invalid: Order Passed Despite Stay on Further Proceedings

January 15, 2026 456 Views 0 comment Print

The Court set aside an assessment passed despite an existing stay order, holding that proceedings undertaken in violation of judicial restraint cannot stand.

Mechanical Reliance on Suspicious Transaction Report: Gujarat HC Quashes Section 148 Reassessment Notice

January 14, 2026 594 Views 0 comment Print

The issue was whether reassessment could be initiated without material showing income had escaped assessment. The Court held that mere allegations of circuitous transactions were insufficient. The key takeaway is that actual escapement is mandatory under the amended law.

Statement of Reportable Account Data Not Conclusive: ITAT Chennai Bars Income Addition Without Verification

January 14, 2026 309 Views 0 comment Print

The Tribunal found that additions for securities transactions may overlap with amounts already accepted by the tax authority. The matter was remitted to the AO for factual verification before sustaining any addition.

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