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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


Reassessment Order Set Aside After GST Proceedings Closure on Same Issue

November 8, 2025 852 Views 0 comment Print

Delhi High Court set aside the Section 148A(3) reassessment order against Vedanta, ruling that subsequent GST Department closure of the underlying ITC issue materially affects the basis of escapement of income. The matter was remanded for a fresh decision incorporating the GST clean chit on the same transaction.

Reassessment on Wound-Up Foreign FPI Held Void: ITAT Quashes ₹456 Cr Addition

November 7, 2025 585 Views 0 comment Print

ITAT Delhi ruled that a reassessment notice served under Section 148 on a foreign FPI (Singapore company) after its formal dissolution is void ab initio. This decision confirms that proceedings against a non-existent entity, even if served shortly after winding up, are invalid and cannot be cured by Section 292B.

Reassessment notice u/s. 148 quashed as issued after expiry of limitation period prescribed u/s. 149

November 7, 2025 1272 Views 0 comment Print

Karnataka High Court held that issuance of reassessment notice under section 148 of the Income Tax Act after expiry of statutory period of limitation as prescribed under section 149 of the Income Tax Act is liable to be quashed. Accordingly, petition allowed.

HC Quashes Reassessment as Jurisdictional AO Violated Faceless Scheme

November 6, 2025 723 Views 0 comment Print

The Karnataka High Court set aside the reassessment proceedings, including Section 148A and consequential penalty orders, ruling they were initiated without jurisdiction. The court found that the jurisdictional AO issued notices outside the scope of Section 151A, violating the CBDT’s faceless scheme.

ITAT Deletes Rs.31 Cr Addition: No Fresh Material to Disprove Genuine Investments

November 6, 2025 288 Views 0 comment Print

The Kolkata ITAT deleted a Rs.31 crore unexplained cash credit addition under Section 68 on the sale of shares, ruling the AO mechanically relied on an investigation report without fresh evidence. The tribunal held that investments accepted by the Department in previous years and confirmed via an NCLT merger cannot be summarily taxed upon sale.

Section 148 Notice Issued After Limitation Quashed by Karnataka High Court

November 5, 2025 1452 Views 0 comment Print

Karnataka High Court held that a reassessment notice issued on 7 May 2024 for AY 2017–18 was beyond six-year limitation period under Section 149 of Income Tax Act and therefore invalid.

AP HC Quashes Reassessment Notices Issued Outside Faceless Scheme – JAOs Lack Jurisdiction Under Section 151A

November 4, 2025 1326 Views 0 comment Print

The Andhra Pradesh High Court definitively ruled that Jurisdictional Assessing Officers (JAOs) lack the authority to issue reassessment notices (u/s 148A/148) after the Faceless Assessment Scheme (Section 151A) was notified in 2022. The court quashed the notices and orders, establishing that the faceless mechanism is the exclusive forum for initiating reassessment proceedings.

ITAT Remands Case 1% Commission on ₹44.5 Cr Conduit Deals for Fresh Verification

November 4, 2025 252 Views 0 comment Print

The ITAT Delhi set aside an addition of Rs.44.50 lakh, alleged as commission income on fund routing transactions, due to the CIT(A)’s failure to pass a speaking order. The Tribunal remanded the case to the AO for a fresh, de novo assessment to verify documents and provide reasoned findings, ensuring compliance with natural justice.

Delhi HC Quashes Reassessment Based on New Grounds Not Mentioned in 148A(b) Notice

November 4, 2025 807 Views 0 comment Print

Reassessment based on a new Permanent Establishment (PE) ground, which was absent from the initial notice, was quashed by the Delhi High Court. The court ruled that tax authorities must adhere strictly to the grounds stated in the statutory notice.

FAQs on Assessments under Income-tax Law

November 4, 2025 93186 Views 7 comments Print

Learn about various types of income tax assessments under Sections 143, 144, and 147, their procedures, time limits, and taxpayer rights under the Income Tax Act, 1961.

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