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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 108 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 336 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 219 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 207 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


Jurisdiction of JAO to conduct proceedings u/s. 148A: Matter referred to Larger Bench

July 4, 2025 2484 Views 0 comment Print

Madras High Court held that the question of jurisdiction of Jurisdictional Assessing Officer (JAO) to conduct proceedings under section 148A of the Income Tax Act is referred to Larger Bench. Accordingly, writ disposed of.

Reassessment notice sustainable as issued within extended time limit under TOLA

June 30, 2025 933 Views 0 comment Print

Vide the present petition, the petitioner has challenged notices and orders issued under section 148 of the Income Tax Act. Impugned Notice dated 31.03.2021 was issued under Section 148 of the Income Tax Act, 1961 as in force till 31.03.2021.

TOLA extension Do Not Alter Specified Authority under Section 151: Delhi HC

June 25, 2025 1044 Views 0 comment Print

Delhi High Court sets aside Section 148 income tax notice for Bhagwan Sahai Sharma, ruling it invalid due to lack of proper prior approval from the specified authority under Section 151(ii) of the IT Act.

Section 148 Notice to Non-Existent Amalgamated Company Is Void: ITAT Mumbai

June 24, 2025 1311 Views 0 comment Print

Since the notice was issued under Section 148 in the name of a non-existing entity, despite the department having been intimated about the amalgamation much earlier, the impugned notice under Section 148 was null and void. Consequently, the reassessment order passed based on this invalid notice was quashed.

Section 148A Proceedings Invalid If Assessee’s Response Rejected Solely Based on Portal Information

June 21, 2025 1662 Views 0 comment Print

Delhi High Court sets aside Section 148A(d) order and 148A(b) notice for Devat And Ram Company, finding AO rejected assessee’s response based solely on portal information.

Notice U/S 148 Invalid if issued Without Proper Section 151 Sanction: Delhi HC

June 20, 2025 2019 Views 0 comment Print

Delhi High Court held that notice issued u/s. 148 and assessment order thereon is liable to be set aside as sanction of issuance of notice not granted by authority specified under section 151 of the Income Tax Act. Accordingly, appeal of asset allowed and demand set aside.

Prior Approval U/S 151 Mandatory for Notices U/S 148 Issued Beyond 3 Years, Even Under Extended TOLA Timelines

June 19, 2025 1473 Views 0 comment Print

Delhi High Court held that prior approval u/s. 151 for issuance of notice under section 148 of the Income Tax Act beyond period of three years mandatory even in case of extended limitation under TOLA. Accordingly, notice and order thereon set aside.

Delhi HC Quashes Reassessment Notice, TOLA Can’t Extend Limitation on or after April 1, 2021

June 18, 2025 891 Views 0 comment Print

Delhi High Court quashes reassessment notice for AY 2015-16, citing Supreme Court’s Rajeev Bansal judgment and Revenue’s concession on notices issued post-April 2021.

ITAT Remands Case to CIT(A) for Fresh Adjudication Due to Lack of Proper Hearing

June 17, 2025 660 Views 0 comment Print

Patna ITAT remands case for fresh CIT(A) hearing, finding assessee was denied proper opportunity to present case and CIT(A) failed to address merits.

Section 148A(d) Order passed without cogent or plausible reasons is invalid: HP HC

June 17, 2025 495 Views 0 comment Print

Himachal Pradesh High Court held that since order passed under section 148A(d) of the Income Tax is bereft of any cogent or plausible reasons the same is liable to be set aside. Accordingly, matter remanded back to AO to decide afresh.

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