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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


Rs. 50 Lakhs limit Not Applicable to section 148A(b) issued within 3 years

October 17, 2022 3963 Views 0 comment Print

Ester Industries Ltd Vs ACIT (Delhi High Court) High Court is of the view that the condition precedent of an asset in the form of Rs.50 lakhs is not be attracted to the present case, as the notice under Section 148A(b) of the Act had been issued on 17th March, 2022 i.e. within three years […]

Petitioner has right to get adequate time under Section 148A to respond to SCN

October 17, 2022 1356 Views 0 comment Print

Bird Worldwide Flight Services (I.) Pvt. Ltd Vs DCIT (Delhi High Court) Court is of the view that the Petitioner has a right to get adequate time under Section 148A of the Act to respond to the show cause notice. It is pertinent to mention that Section 148A(b) of the Act permits the Assessing Officer […]

Issuance of notice u/s 148A based on adequate information is tenable

October 13, 2022 3069 Views 0 comment Print

Orissa High Court held that notice issued u/.s 148A of the Income Tax Act clearly demonstrates that the Assessing Authority had in possession of information about deposit of cash in the banks and hence the same is tenable in law

HC quashes Section 148A order for not-providing sufficient information

September 21, 2022 2886 Views 0 comment Print

High Court held that reasons provided to the petitioner did not contain any information but it is titled as ‘cash related information detail’ and such information cannot be said to be sufficient for reopening of the assessment.

Section 148 Notice valid If Assessee failed to submit Crypto Currency Ledger

September 20, 2022 2697 Views 0 comment Print

Assessee to satisfy the authority by submitting Crypto currency ledger to verify information as was submitted by him before AO in proceedings under Section 148A

Reassessment when Income Tax Act not provide for it – Application of Article 142

September 18, 2022 5631 Views 1 comment Print

Can the I-T department call for reassessment when the Income Tax Act, 1961 does not provide for it – Per Incuriam application of Article 142

Reopening of assessment based on Investigation Report of other Assessee justified

September 18, 2022 2439 Views 0 comment Print

S. Raheja Realty Pvt. Ltd. Vs Office of Income Tax Officer (Gujarat High Court) On perusal of the Explanation (1) of the Section 148, it is clear that that for the purpose of Section 148A, the information with the Assessing Officer which suggests that the income chargeable to tax has escaped assessment means any information […]

Delhi HC allows reopening of AY 2013-14 till 30th June, 2021

September 18, 2022 3690 Views 0 comment Print

Touchstone Holdings Pvt. Ltd. Vs ITO (Delhi High Court) Delhi High Court allows reopening of AY 2013-14 (despite being beyond 6 years from 1st April 2021), basing on extension as per Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The time limit for issuing notice under unamended Section 149 which […]

Audit Objection cannot be basis of AO’s ‘Reasons to Believe’ after lapse of time period of 6 Years

September 13, 2022 2853 Views 0 comment Print

An audit objection did not satisfy the requirement of AO having an independent ‘reason to believe’ that income had escaped assessment, that too after the elapse of nearly six years from the end of the relevant assessment year, therefore, the impugned reassessment proceedings were vitiated.

Reassessment Proceedings against Reassessment order Stayed by Delhi HC

September 13, 2022 4446 Views 0 comment Print

United Associates Vs ITO (Delhi High Court) A Writ Petition was filed in Hon’ble Delhi high Court to set aside the notice dated 28.06.2022 issued by the Income Tax Department under section 148 of the Income Tax Act, 1961 and order u/s 148A(d) issued by the Respondent No.1 under section 148 of the Income Tax […]

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