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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 27 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 27 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 33 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


Section 148A(d) Order Not Appealable, Writ Jurisdiction Available: MP HC

December 29, 2024 2391 Views 0 comment Print

Given that the order under Section 148A(d) was not appealable, the court ruled that the petitioner had no alternative remedy and set aside the order.

Order set aside as AO erroneously added value of transaction for calculating escaped assessment

December 28, 2024 420 Views 0 comment Print

Delhi High Court held that AO has erroneously added value of transaction while calculating income that could possibly have escaped assessment. Accordingly, order set aside and matter remanded back to AO for fresh consideration.

Contribution to Approved Superannuation Fund Deductible if not exceeds Prescribed Limit: ITAT Kolkata

December 28, 2024 501 Views 0 comment Print

These regulations do not specify any date by which the employee’s contribution/ subscription to the PF is to be deposited in the individual employee’s account under the Calcutta Port Trust Non-Contributory Provident Fund.

Initiation of reassessment proceedings against dead person illegal: Kerala HC

December 27, 2024 1023 Views 0 comment Print

The assessee, expired on 30.10.2021. Notice dated 27.03.2023 u/s. 148A(b) of the Act was served on the address of the late assessee. The said notice was with respect to the assessment year 2019-2020.

Reasons disclosed to assessee for reassessment u/s. 148 cannot be improved subsequently: Delhi HC

December 25, 2024 4833 Views 0 comment Print

Delhi High Court held that validity of reassessment under section 148 of the Income Tax Act has to be determined based on original reasons disclosed to the assessee. Such reasons cannot be improved upon subsequently.

Material indicating purchase from non-existing entities can be basis for reassessment u/s. 148

December 24, 2024 786 Views 0 comment Print

The petitioner has filed the present petition, inter alia, impugning a notice dated 22.03.2024 issued u/s. 148A(b) of the Income Tax Act, 1961 as well as the order dated 31.03.2024 issued u/s. 148A(d) of the Act.

Assessment Ignoring Indexed Cost of Acquisition Set Aside: Karnataka HC

December 23, 2024 993 Views 0 comment Print

Devanur Thimmasetty Srinivasa Vs ITO (Karnataka High Court) Assessment order taking entirety of the sale consideration without taking note of the indexed cost of acquisition. is liable to set-aside- Karnataka HC In a recent ruling, the Karnataka High Court quashed an income tax reassessment order and notice issued to the petitioner where the full sale […]

Reassessment Based on Insight Portal Info Must Be Under Sections 147/148 if Section 153C Jurisdictional Conditions Are Not Met

December 20, 2024 1938 Views 0 comment Print

Assessee argued that AO lacked jurisdiction to initiate proceedings under Section 147/148 as the information derived from the search should had been assessed under Section 153C.

Notice issued u/s. 148 after period of six years for AY 2015-16 is barred by limitation: ITAT Mumbai

December 19, 2024 35559 Views 0 comment Print

ITAT Mumbai held that validity of notice issued under section 148 of the Income Tax Act for AY 2015-16 is six year which expires on 31.03.2022. Accordingly, notice issued on 29.07.2022 u/s. 148 is barred by limitation.

Reopening Based on Internal Audit Memo Unsustainable Before Section 148 Amendment: ITAT Mumbai

December 12, 2024 1182 Views 0 comment Print

ITAT Mumbai held that the internal audit memo is outside the scope and ambit of the term “information” as provided in Explanation 1 to section 148 of the Act, prior to its amendment by the Finance Act, 2022. Accordingly, reopening of proceedings liable to be quashed.

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