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Section 148A

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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 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 4401 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


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 78 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 63 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 66 Views 0 comment Print

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 108 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


Telangana HC Quashes Reassessment by Jurisdictional AOs After Faceless Scheme Implementation

May 20, 2026 135 Views 0 comment Print

The Telangana High Court held that reassessment proceedings initiated by the Jurisdictional Assessing Officer after implementation of the Faceless Assessment Scheme were without jurisdiction. It quashed notices issued under Sections 148A and 148 along with consequential orders.

Unsigned Digital Reassessment Notices Held Void – ITAT Quashes Entire 147 Proceedings

May 19, 2026 207 Views 0 comment Print

Delhi ITAT held that notices issued under Sections 148A(b), 148A(d) and 148 without digital signatures are invalid in e-proceedings. The Tribunal quashed the entire reassessment as void ab initio.

Section 54 Exemption Allowed as Investment Was Made Within 2 Years Despite No CGDS Deposit

May 18, 2026 399 Views 0 comment Print

ITAT Indore held that Section 54 exemption cannot be denied merely for failure to deposit capital gains in the Capital Gain Deposit Scheme. The Tribunal ruled that actual investment in a new residential house within the prescribed two-year period satisfies the substantive requirement.

Reassessment Quashed for Ignoring Reply Filed Under Section 148A(b): ITAT Slams ‘Borrowed Satisfaction’

May 18, 2026 174 Views 0 comment Print

The Tribunal held that reassessment proceedings were invalid where the Assessing Officer ignored the assessees detailed response and documentary evidence. ITAT ruled that such action violated principles of natural justice and reflected non-application of mind.

Hyderabad ITAT Quashes AY 2015-16 Reopening – Notice u/s 148 Issued After 6 Years Held Time-Barred Despite ₹50 Lakh Escape Claim

May 18, 2026 162 Views 0 comment Print

Hyderabad ITAT held that a notice issued under Section 148 after six years from the end of AY 2015-16 was invalid. The Tribunal ruled that the amended 10-year reopening provision cannot revive already time-barred cases.

Chennai ITAT Quashes Reassessment – Notice u/s 148 Beyond 3 Years Needs PCCIT Approval, Not PCIT Approval

May 18, 2026 210 Views 0 comment Print

Chennai ITAT held that reassessment notices issued after three years must comply strictly with Section 151(ii) approval requirements. Failure to obtain sanction from the proper authority vitiated the entire reassessment proceedings.

ITAT Restores Section 80P Claim as Delay Condonation Petition Was Pending

May 15, 2026 156 Views 0 comment Print

The ITAT Chennai restored the assessment matter to the Assessing Officer after noting that the assessee’s condonation petition under Section 119(2)(b) was still pending. The Tribunal held that the decision on condonation directly affected eligibility for deduction under Section 80P.

Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

May 13, 2026 399 Views 0 comment Print

ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-examine the person whose statement forms the basis of the assessment. The Tribunal ruled that reliance on such untested statements violates principles of natural justice and renders the addition legally unsustainable.

No Cross-Examination, No Addition: ITAT Deletes ₹1.09 Crore “Entry Operator” Loan Addition

May 12, 2026 414 Views 0 comment Print

ITAT Mumbai held that addition under Section 69A could not survive when based solely on a third-party statement without granting cross-examination. The Tribunal ruled that denial of cross-examination violated principles of natural justice.

Reassessment Invalid Where Seized Document Did Not Match Agricultural Land Sale: Gujarat HC

May 11, 2026 204 Views 0 comment Print

The Gujarat High Court quashed reassessment proceedings after finding that the seized loose paper referred to non-agricultural land rates recorded after the petitioner had already sold agricultural land. The Court held that reopening based on hypothetical assumptions and unrelated material was unsustainable.

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