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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 330 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


Section 148 notice to NRI Without Mandatory Faceless Procedure Unsustainable: Telangana HC

August 17, 2024 2556 Views 0 comment Print

Telangana High Court held that notice issued u/s. 148 of the Income Tax Act must comply with the requirement of the Scheme whether or not the Taxpayer is NRI/Indian Citizen. Thus, issuance of notice to NRI u/s. 148 without following mandatory faceless procedure is set aside.

Notice u/s. 148A issued by Jurisdictional AO instead of Faceless AO liable to be quashed: Bombay HC

August 17, 2024 6339 Views 0 comment Print

Bombay High Court held that issuance of notice under section 148A of the Income Tax Act by Jurisdictional Assessing Officer and not by a Faceless Assessing Officer as required by the provisions of section 151A of the Income Tax Act is liable to be quashed.

Form 10 Submitted Electronically Before Assessment Completion; Reopening Due to Technical Delay Unjustified

August 16, 2024 672 Views 0 comment Print

Delhi HC quashes reopening of tax assessment, ruling that technical delay in e-filing Form 10 before assessment completion is unjustified. Case: FY 2016-17.

Written request to existing AO needs to be made for migrating PAN to new AO due to address change: Patna HC

August 13, 2024 1812 Views 0 comment Print

Patna High Court held that for migrating PAN to new AO, due to change in address, a written request to existing AO must be made. Such procedure needs to be followed for change of jurisdiction.

Reassessment unsustained as based on entirely new reason which deprives assessee’s right to object: Delhi HC

August 12, 2024 924 Views 0 comment Print

Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning deprives assessee’s right to effectively object the proposed reassessment action. Accordingly, the impugned action is rendered wholly unsustainable.

Validity of initiation of reassessment u/s. 147 and 148 must be independently evaluated: Delhi HC

August 10, 2024 1377 Views 0 comment Print

The department issued notice u/s. 148A(b) of the Income Tax Act, 1961, alleging that the petitioner had received loan from its 100% subsidiary i.e., Gul Properties Pvt. Ltd.

Reassessment alleging delayed filing of Form 10 without opinion of income escaped assessment untenable: Delhi HC

August 10, 2024 594 Views 0 comment Print

Associated Chambers of Commerce And Industry of India Vs Deputy Commissioner of Income Tax & Ors. (Delhi High Court) Delhi High Court held that action of reassessment merely on the allegation of delayed digital filing of Form 10 without based on the formation of an opinion that income chargeable to tax has escaped assessment. Facts- […]

Initiation of re-assessment proceedings merely based on faceless information quashed: Bombay HC

August 7, 2024 2166 Views 0 comment Print

Bombay High Court held that initiation of re-assessment proceedings u/s. 148 of the Income Tax Act without verifying the information derived from the mechanism of faceless collection of information is unsustainable and liable to be quashed.

Note on Income Tax Notices Issued: Section148 read with Section 135A

July 31, 2024 6321 Views 1 comment Print

Learn about the revised procedure for reopening cases under Section 148 RWS 135A and the implications of Finance Act 2021, including key judicial decisions.

Faceless assessment doesn’t permit issuance of notice u/s. 148A(b) by Jurisdictional AO: Bombay HC

July 30, 2024 2445 Views 0 comment Print

Bombay High Court held that it was not permissible for the Jurisdictional Assessing Officer to issue a notice under Section 148A(b), as the same would amount to breach of the provisions of section 151A of the Income Tax Act (i.e. faceless assessment scheme).

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