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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 105 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 321 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 210 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 201 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


Initiation of Reassessment Proceedings by Non-Jurisdictional ITO is invalid

June 17, 2022 870 Views 0 comment Print

Indus Towers Ltd Vs Income Tax Officer (Delhi High Court) Having perused the letter dated 9th May, 2022 written by the Income Tax Officer, Ward 6(2), Jaipur, this Court is of the view that the said Income Tax Officer had no jurisdiction to issue notice dated 14th March, 2022 to propose initiation of reassessment proceedings, […]

SC judgment not applies to Section 148 notice for AY 2013-14 to 2015-16

June 15, 2022 14832 Views 0 comment Print

Ajay Bhandari Vs Union of India (Allahabad High Court) Reassessment — Reopening of assessment — Reopening notice issued under unammended provisions — Reliefs sought in petition is to quash impugned notice u/s 148 — Held, as per Clauses 6.2 and 7.1 of Board’s Circular dated 11.05.2022, if a case does not fall under Clause (b) […]

Give Assessee opportunity of hearing before passing Section 148A order: HC

June 11, 2022 1791 Views 0 comment Print

Inner Wheel Club of Central Calcutta Vs Union of India & Ors. (Calcutta High Court) HC directs Income Tax Authorities to consider Representations made on 25/03/2022 and subsequent dates and then pass Order under sec 148A(d). They have been also directed to give the assessee opportunity of hearing. FULL TEXT OF THE ORDER OF CALCUTTA […]

Draft of Reply to Section 148A(b) Notice considering SC Order

June 10, 2022 90495 Views 4 comments Print

Craft a strong response to Section 148A(b) Notice under the Income Tax Act, 1961. Leverage the Supreme Court order in Union of India vs. Ashish Agarwal dated 04-05-2022 to challenge and defend against the notice.

Section 148 Notice: Format of Reply on Letter Issued by AO Pursuant to SC Order

June 7, 2022 77940 Views 0 comment Print

Honorable Apex Court, in it’s judgment, in Para 10(iv) says as under: All defenses which may be available to the assesses including those available under section 149 of the IT Act and all rights and contentions which may be available to the concerned assessee and Revenue under the Finance Act, 2021 and in law shall continue to be available.

Summarised response to notices issued u/s 148A subsequent to SC decision & CBDT instruction No. 01/2022

June 3, 2022 16107 Views 1 comment Print

Understanding the impact of SC decision & CBDT instruction on reassessment notices u/s 148A. Learn how to reply to these notices for AYs 2013-14 & 2014-15.

Recent Supreme Court Decision on Reassessment

June 1, 2022 12624 Views 2 comments Print

Understanding the recent Supreme Court decision on reassessment notices issued under the Income-tax Act, 1961. Find out the impact on ongoing litigation.

Is CBDT instruction on issue of section 148 notice legally incorrect?

May 30, 2022 41820 Views 10 comments Print

An analysis of the legal correctness of CBDT Instruction No. 01/2022 and its implications on section 148 notices under the Income Tax Act.

HC directs proceeding against officers passing erroneous order

May 29, 2022 4998 Views 0 comment Print

Dharmendra Kumar Singh Vs Union of India (Allahabad High Court) Instruction F. No. 225/101/2021/-ITA-II, dt. 25/04/22 provides for initiation of suitable administrative action against the erring officer in case where assessments are found by the local committee to be high-pitched or where there is non-observance of principles of natural justice, non- application of mind or […]

New scheme of reassessment u/s 147- is it really reducing litigation

May 19, 2022 5928 Views 0 comment Print

Explore the impact of the new reassessment scheme u/s 147 under the Income Tax Act. Is it really reducing litigation and promoting ease of doing business? Find out.

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