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Section 148A

Latest Articles


Landmark Rulings on Reassessment u/s 148 – Post 2021 Amendments

Income Tax : Explore key court rulings on reassessment under Section 148 post-2021 amendments, covering procedural changes, taxpayer rights, an...

February 7, 2025 2580 Views 0 comment Print

Draft Submissions on Section 148A(b) Notice Issued Based on wrong Information

Income Tax : Written submission against wrong cash deposit notice under Section 148A(b), highlighting errors and lack of independent inquiry....

December 7, 2024 2436 Views 0 comment Print

Note on SC Ruling in Rajeev Bansal Case and Its Impact on Pending Cases

Income Tax : The Supreme Court’s Rajeev Bansal case clarified the validity of reassessment notices for AY 2013-14 to 2018-19 and introduced t...

November 13, 2024 3645 Views 0 comment Print

Implications & Issues Surrounding Supreme Court Rulings on Reassessment Notices: Analysis

Income Tax : The Supreme Court's rulings clarify reassessment procedures under the Income Tax Act, addressing validity, TOLA implications, and ...

October 8, 2024 1935 Views 0 comment Print

Interpreting Reassessment Provisions – UOI vs. Rajeev Bansal & Ors (SC)

Income Tax : The Supreme Court ruling in UOI vs. Rajeev Bansal clarifies reassessment provisions post-April 2021 under Income Tax Act, extendin...

October 5, 2024 5613 Views 1 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 2490 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 6567 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 7044 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 8430 Views 0 comment Print


Latest Judiciary


Reopening assessment without controverting explanation of assessee is bad-in-law: ITAT Kolkata

Income Tax : ITAT Kolkata held that reopening of assessment framed u/s. 148A(d) without application of mind and without controverting the expla...

March 6, 2025 84 Views 0 comment Print

Gujarat HC quashed Section 148 notice for failure to address objections

Income Tax : Deloitte Haskins And Sells Vs ACIT (Gujarat High Court) The High Court recently adjudicated a case concerning a writ petition file...

March 6, 2025 1962 Views 0 comment Print

Assessee accountable for transactions by its power of attorney holder: Rajasthan HC

Income Tax : Rajasthan High Court rejected Agarwal Polysacks' plea against IT reassessment under Section 147, holding the company accountable f...

March 6, 2025 507 Views 0 comment Print

Order Passed U/S 148 Overlooking Apparent Error Not Sustainable: Delhi HC

Income Tax : Delhi High Court held that provision of section 292B doesn’t include passing of order u/s. 148 overlooking error apparent on the...

March 5, 2025 567 Views 0 comment Print

JAO can issue Section 148 notice after Section 132 search: Gujarat HC

Income Tax : Gujarat High Court rules that a jurisdictional assessing officer cannot override the faceless assessment scheme under Section 151A...

March 4, 2025 1305 Views 0 comment Print


Latest Notifications


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 5511 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 3021 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 14985 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 14058 Views 0 comment Print

Revised Guideline for Issue of Section 148 Notice

Income Tax : Salient features of new Section 148 to 151A 'i.e. assessment/reassessment procedure of Income Escaping Assessment...

August 1, 2022 82191 Views 1 comment Print


Delhi HC dismisses reassessment notices issued after 31.03.2021 in 1346 cases

December 15, 2021 18786 Views 0 comment Print

Mon Mohan Kohli Vs ACIT & Anr. (Delhi High Court) This Court is of the view that as the Legislature has introduced the new provisions, Sections 147 to 151 of the Income Tax Act, 1961 by way of the Finance Act, 2021 with effect from 1st April, 2021 and as the said Section 147 is […]

CBDT notifications not empowers department to put into oblivion section 148A provisions

December 12, 2021 2673 Views 0 comment Print

JSVM Plywood Industries Ltd Vs Union of India (Gauhati High Court) Prima facie opinion of the Court, for the purpose of interim order, is that by virtue of notifications dated 27.02.2021 and 31.03.2021 issued by the Central Board of Direct Taxes, as referred herein before, though extends the period of limitation in respect of issuance […]

Is it be Possible to Re-Open Assessment only Because of Change of Opinion?

December 5, 2021 1881 Views 0 comment Print

We know that provisions of sections 147 to 151 of the Income Tax Act, 1961 deal with Reassessment of and escaped assessment of income of an assessee. Income Tax Officer under these provisions reassess by reopening the cases assessed earlier on the believe that incomes or profits or gains chargeable to income tax has escaped […]

Rajasthan HC quashed Section 148 notice issued on or after 01.04.2021 in 237 cases

December 4, 2021 11832 Views 0 comment Print

Bpip Infra Private Limited Vs ITO (Rajasthan High Court) In these cases petitioners are aggrieved of issuance of the re-assessment notice u/s.148 of the Income Tax Act, 1961, which according to the petitioners are barred by limitation and that the Department before issuing the notice under Section 148 of the Act has not followed the […]

HC upheld validity of Section 148 Notice issued after 31.3.2021

September 13, 2021 3816 Views 0 comment Print

Ashok Kumar Agrawal Vs Union of India (Chhattisgarh High Court) It is submitted that on the date i.e. on 28.06.2021 when the notice under Section 148 of the Income Tax Act is issued, the power to issue the notice was preceded with a new provision of law and thereby Section 148 is to read with […]

Section 148: Can same Twins be inter-changed for convenience?

September 6, 2021 4245 Views 1 comment Print

Compare a situation where there is a pair of same-twin, one of whom is your employee. For some purposes, whether the sibling brother of your employee can replace your employee just because he is same-looking? The reason for the title because the Finance Act, 2021 has substituted section 148 with effect from 1-Apr-2021 and a […]

Twist in the Tale – Old Section 148 vs. New section 148A Controversy

September 5, 2021 34635 Views 6 comments Print

The deferment of application of old provisions of section 148 was done by the CBDT, Ministry of Finance by way of conditional legislation in the peculiar circumstances which arose during the pandemic and lock down. Hence, there being no full delegation of powers in the scenario, the Central Government cannot be said to have encroached upon turf of Parliament.

Interim Protection against Section 148 Notice by MP High Court

September 4, 2021 1674 Views 0 comment Print

Jagadish Kumar Basantani Vs ITO Bhopal and Others (Madhya Pradesh High Court) Regard being had to the similitude of the questions involved, on the joint request of the parties, the matter is being heard on the question of admission and interim relief. Learned counsel for the petitioner submits that the petitioner has challenged the Constitutionality […]

Latest Development in Section 148 Notices Issued After 31st March 2021

September 3, 2021 18783 Views 2 comments Print

The Finance Act, 2021 introduced a new set of reassessment proceedings from 01.04.21.The Central Board of Direct Taxes (C.B.D.T)  by way of various notifications had extended the time limit of issuing the notice U/s 148 of the Act up to  30th June, 2021. The Income tax department has issued many Section 148 notices for several […]

HC upheld validity of section 148 notices issued between 01.04.2021 to 30.06.2021 without following section 148A procedure

September 2, 2021 28029 Views 0 comment Print

Palak Khatuja Vs Union Of India (Chhattisgarh High Court) 1. The time for issuance of notice under Section 148, the end date was initially extended uptill on 30th day of April 2021 and subsequently again by notification dated 27th April, 2021 the time limit of 30th day of April 2021 was further extended up till […]

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