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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


Reopening u/s. 148 merely on the basis of change of opinion is bad-in-law

May 17, 2025 1956 Views 0 comment Print

ITAT Jaipur held that reopening under section 148 r.w.s. 148A is bad-in-law and liable to be quashed in as much as reopening was merely on the basis of change of opinion. Accordingly, appeal of assessee allowed and reopening quashed.

Delhi HC Quashes AY 2015-16 Section 148 Reassessment Notice

May 14, 2025 1368 Views 0 comment Print

Delhi High Court sets aside a Section 148 income tax reassessment notice for Assessment Year 2015-16, ruling it time-barred based on the Revenue’s concession in a Supreme Court case.

No reassessment proceedings as the limitation period u/s 149 was expired

May 14, 2025 4350 Views 0 comment Print

Assessee challenged this, arguing the procedure under Section 148A was not followed. The Supreme Court ruled that notices after 31.03.2021 had to follow the amended Section 148A.

Forum Convenience Principle Favors Remedies in Kolkata as Cause of Action Originated There: Bombay HC

May 12, 2025 603 Views 0 comment Print

Thus, a substantial portion of the cause of action has accrued at Kolkata. Applying the principle of forum convenience, it would be appropriate if the petitioner was relegated to availing of the remedies at Kolkata.

Reassessment notice u/s. 148 quashed as approval prescribed under amended section 151 not obtained

May 12, 2025 1614 Views 0 comment Print

ITAT Rajkot held that the reassessment notice under section 148 of the Income Tax Act has been issued without obtaining the approval as prescribed under amended provision of section 151 of the Act is liable to be quashed. Accordingly, appeal of assessee allowed.

Section Notice liable to be quashed if not supported by reasons: Patna HC

May 10, 2025 4089 Views 0 comment Print

Patna High Court held that notice must be supported by reasons. Accordingly, since notice issued under section 148 of the Income Tax Act is not supported by reasons the same is liable to be quashed. Thus, writ petition stand allowed.

Rajasthan HC Dismisses Writ Petition for Non-Exhaustion of Statutory Remedies in Reassessment Case

May 10, 2025 468 Views 0 comment Print

Rajasthan High Court dismisses Bhag Chand Jangid’ s plea against tax assessment due to delayed challenge of the initial order. Alternative remedies available.

Funds from foreign sources into NRE accounts not taxable in India in terms of section 10(4)

May 9, 2025 1065 Views 0 comment Print

ITAT Ahmedabad held that funds remitted from foreign sources into NRE accounts are not taxable in India unless there is material to establish that they originate from taxable Indian income. Accordingly, exemption u/s. 10(4) of the Income Tax Act granted.

Taxpayer ineligible for DTVSV Scheme against notice issued u/s. 148 as disputed tax not ascertained

May 8, 2025 696 Views 0 comment Print

Patna High Court held that taxpayer will not be eligible for Direct Tax Vivad Se Vishwas Scheme 2024 [DTVSV Scheme] against notice issued under section 148 of the Income Tax Act since dispute tax is not ascertainable.

10-Year Reassessment Period Unjustified as Conditions Under Section 153A(1) Not Met

May 8, 2025 3249 Views 0 comment Print

Held that the AO seeks to disallow expenses on account of doubting the genuineness for the reason that the same were not incurred wholly or exclusively for the purpose of the petitioner’s business.

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