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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


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 60 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 42 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 51 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


Both Jurisdictional and Faceless Officers Can Issue Reassessment Notices: Delhi HC

October 6, 2025 1125 Views 0 comment Print

Delhi High Court held that under Section 148A of the Income Tax Act, both the Jurisdictional Assessing Officer and Faceless Assessing Officer possess concurrent jurisdiction to issue reassessment notices, reaffirming its earlier ruling in TKS Builders Pvt. Ltd.

Delhi HC Confirms Concurrent Jurisdiction of JAO and FAO for Section 148 Proceedings

October 6, 2025 918 Views 0 comment Print

Reiterating its view from K.S. Builders Pvt. Ltd., the Delhi HC held that both Jurisdictional and Faceless Assessing Officers have concurrent powers to issue reassessment notices under Section 148 of the Income Tax Act.

No Exclusive Right for Faceless AO: Delhi HC Reiterates Dual Jurisdiction Under Section 148

October 6, 2025 621 Views 0 comment Print

Delhi High Court’s ruling in Neena Wadhwa v. PCIT upholds the concurrent power of both the Jurisdictional Assessing Officer (JAO) and the Faceless Assessing Officer (FAO) to issue reassessment notices under Section 148, citing the binding precedent of T.K.S. Builders Pvt. Ltd..

Jurisdictional AO Cannot Issue Notice u/s 148 After Faceless Mandate: ITAT Delhi

October 4, 2025 2502 Views 0 comment Print

ITAT Delhi allows NRI’s appeal in Chirag Kirpal Vs ACIT, ruling that the Jurisdictional AO (JAO) lacks the power to issue a Section 148 notice after the Faceless Reassessment Scheme (s.151A) took effect.

SC Disposes Revenue Appeal Against Reassessment Notice Quashing

October 4, 2025 924 Views 0 comment Print

The Supreme Court of India disposed of the Revenue’s appeal against the Delhi High Court’s order quashing reassessment notices against Trans World International Ltd.

Order passed by AO in old PAN cannot be survived if transactions already reported in new PAN

September 30, 2025 591 Views 0 comment Print

ITAT Hyderabad held that assessment order passed by AO in old PAN cannot be survived if transactions reported by DGFT in old PAN is already reported by assessee in new PAN. Accordingly, matter restored back to re-verify.

ITAT Delhi Quashes Reassessment– Wrong Authority’s Approval Invalidates 148 Notice

September 28, 2025 663 Views 0 comment Print

ITAT Delhi quashes reassessment (AY 2016-17) and deletes Rs.2.25 Cr LTCG addition after finding that PCIT, not PCCIT, gave the required Section 151 approval.

Laptop Data Alone Cannot Justify Reopening u/s 148: Excel Sheets Not Books or Assets

September 25, 2025 996 Views 0 comment Print

ITAT Hyderabad rules Excel sheets from an accountant’s laptop aren’t ‘books’ or ‘assets,’ quashing reassessment notices against Exel Rubber for mechanical sanction and insufficient evidence.

Reassessment notice issued after surviving time would be invalid

September 25, 2025 963 Views 0 comment Print

Gujarat High Court held that reassessment show cause notice under section 148 of the Income Tax Act issued after 18.06.2022 i.e. after surviving time’ would be invalid and accordingly, notice is quashed and set aside.

Charter Hire Charges: Royalty or Section 44BB Income? Mumbai Tribunal Orders DRP to Reconsider

September 25, 2025 384 Views 0 comment Print

ITAT Mumbai set aside DRP directions for Celestial Vision Ltd, ruling the DRP mixed up facts, failed to address 44BB applicability, and mistakenly discussed Section 147 reopening procedures.

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