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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


Reassessment Order In the Name of Non-Existing Entity – HC directs AO to pass fresh order

December 1, 2022 1248 Views 0 comment Print

Rajasthan Global Securities Pvt Ltd Vs ACIT (Delhi High Court) 1. Present writ petition has been filed challenging the notice dated 17th April, 2021 issued under Section 148 of the Income Tax Act, 1961 (‘the Act’), notice dated 28th May, 2022 issued under Section 148A(b) of the Act as well as the order dated 27th […]

SC stays reassessment proceedings against Radha Soami Satsang Beas

December 1, 2022 8661 Views 1 comment Print

SC issued notice and stayed proceedings initiated against Radha Soami Satsang Beas on an appeal challenging judgment of Punjab and Haryana HC

HC set aside Section 148A(d) order passed without considering reply of Assessee

November 22, 2022 3978 Views 0 comment Print

Rise Projects Private Limited Vs ACIT (Delhi High Court) Petitioner states that impugned order dated 15th July, 2022 passed under Section 148A(d) of the Act has been passed without considering the detailed reply filed by the petitioner. Learned senior standing counsel for the respondents-revenue, accepts notice. He, on instructions, states that as the petitioner’s contentions have […]

Writ cannot be filed against sufficiency or adequacy of reasons for Income Tax Reassessment

November 4, 2022 597 Views 0 comment Print

Pramod Kumar Vs ACIT (Telangana High Court) HC is of the view that present is not a fit case to interdict the proceedings at the very threshold. Reasons have been assigned by the assessing officer as to why the explanation given by the petitioner could not be accepted. Certainly, such reasons given have a nexus […]

Section 148A(d) Order without considering responses of petitioner is invalid

November 3, 2022 5787 Views 0 comment Print

Ratnagiri Gas And Power Private Limited Vs ACIT (Delhi High Court) A perusal of the paper book reveals that the petitioner’s responses dated 13th June, 2022, and 30th June, 2022, have not been considered by the AO while passing the impugned order under Section 148A(d) of the Act. 11. Consequently, the impugned order passed under […]

HC upheld re-assessment proceeding against alleged bogus LTCG

October 28, 2022 2130 Views 0 comment Print

Vikas Jain Vs ITO (Delhi High Court) In view of the report of DDIT (Inv.) Unit-7(1) and 7(3) Mumbai, shared with the AO which suggests that the LTCG earned by the petitioner in AY 2014-15 was bogus and since, the said LTCG was claimed as exempt income, the AO at this stage, concluded that the […]

Validity of Section 148 notice when escaped assessment is less than Rs.50 lacs

October 19, 2022 20688 Views 1 comment Print

Geeta Agarwal Wife Of Shri Navratan Agarwal Vs ITO (Rajasthan High Court) It is contended that as in the present case, the income, which is alleged to have escaped assessment, is far below Rs.50 lacs i.e., Rs.8 lacs, the bar under clause (a), sub-section (1) of Section 149 of the Act would come into play […]

Assessment order must mention bank details of bogus accommodation entries

October 18, 2022 1809 Views 0 comment Print

Boutique International Pvt Ltd Vs DCIT (Delhi High Court) Court finds that the information furnished to the Petitioner and the impugned order do not specify in which bank account or account number, the alleged amount have been received by the Petitioner. Though the impugned order states that the asset is represented by bogus accommodation entries in […]

Cash deposited during demonetization – HC allows reassessment

October 18, 2022 1695 Views 0 comment Print

Jain Cooperative Bank Limited Vs ACIT (Delhi High Court) As per the notice issued under Section 148A(b) the reassessment proceedings were initiated on the basis of suspicious transactions flagged by the FIU [Financial Intelligence Unit]. It is pertinent to mention that the petitioner is registered as a non-scheduled Urban Co­operative bank who ‘maintained current accounts […]

AO must specify if ITR not been filed by appellant in his Section 148A(b) order

October 17, 2022 1353 Views 0 comment Print

Delhi HC quashes order under Section 148A(d), remands to Assessing Officer. Petitioner to provide sale/purchase deed for fresh decision.

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