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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


Interim Protection against Section 148 Notice by MP High Court

September 4, 2021 1845 Views 0 comment Print

Jagadish Kumar Basantani Vs ITO Bhopal and Others (Madhya Pradesh High Court) Regard being had to the similitude of the questions involved, on the joint request of the parties, the matter is being heard on the question of admission and interim relief. Learned counsel for the petitioner submits that the petitioner has challenged the Constitutionality […]

Latest Development in Section 148 Notices Issued After 31st March 2021

September 3, 2021 19374 Views 2 comments Print

The Finance Act, 2021 introduced a new set of reassessment proceedings from 01.04.21.The Central Board of Direct Taxes (C.B.D.T)  by way of various notifications had extended the time limit of issuing the notice U/s 148 of the Act up to  30th June, 2021. The Income tax department has issued many Section 148 notices for several […]

HC upheld validity of section 148 notices issued between 01.04.2021 to 30.06.2021 without following section 148A procedure

September 2, 2021 28242 Views 0 comment Print

Palak Khatuja Vs Union Of India (Chhattisgarh High Court) 1. The time for issuance of notice under Section 148, the end date was initially extended uptill on 30th day of April 2021 and subsequently again by notification dated 27th April, 2021 the time limit of 30th day of April 2021 was further extended up till […]

Reassessment restrained in 79 cases for not following section 148A procedure

September 2, 2021 3873 Views 1 comment Print

Revenue authorities were restrained from continuing with reassessment till further orders with respect to notices issued on or after 1-4-2021 without following the procedure prescribed under section 148A in 79 cases.

Non-Adherence of SCN under Section 144B invalidates Faceless Assessment

September 1, 2021 1905 Views 0 comment Print

The order rejected the submissions of the petitioner stating that burden to reconcile the data with the service tax returns was on the petitioner and holding that request for further time to be given for reconciliation is not justifiable.

Orissa HC stays section 148 notice issued in violation of section 148A

August 28, 2021 1998 Views 1 comment Print

Charana Panda (HUF) Vs ITO (Orissa High Court) 1. The Petitioner contends that there is violation of Section 148-A of the Income Tax Act, 1961 (‘Act’) and also that the proceedings are time barred. The competency of the officer who issued notice under Section 148 of the Act is also questioned. 2. Issue notice. 3. […]

HC stays section 148 notice issued without complying section 148A

August 2, 2021 3690 Views 0 comment Print

Bhagwati Prasad Jalan Vs  Union Of India And Ors. (Calcutta High Court) The learned Advocate for the respondents is not able to deny the allegations of the petitioners that Section 148A provisions of the Income Tax Act, 1961 was not complied with in this case before issuing notice under Section 148 of the said Act and […]

Controversy of Issue of Section 148 notice without following section 148A procedure

July 31, 2021 4296 Views 0 comment Print

Notice under section 148 of Income Tax Act, 1961 without following the procedure under section 148A issued during  01.04.2021 to 30.06.2021 in relation to AY 2014-15 or earlier  assessment years. A Controversy By way of various notifications issued under section 3 of the Taxation and Other Laws (Relaxation and Amendment Of Certain  Provisions) Act, 2020 […]

Time period for Issue of section 148 notice wef 1.4.2021

July 30, 2021 173319 Views 66 comments Print

Time period for issuance of notice under section 148 under new regime wef 1.4.2021. As per substituted section 149 wef 1.4.2021 As per substituted section 149, no notice shall be issued   for the relevant assessment year if: (a) 3 years have elapsed from the end of the relevant assessment year, unless the case falls under […]

How to deal with Section 148 Notice issued after 31st March 2021?

July 29, 2021 9993 Views 0 comment Print

The Finance Act, 2021 introduced a new set of reassessment proceedings from 1st April 2021.After such substitution, the Old provisions relating to Reassessment, do not survive. The Central Board of Direct Taxes (C.B.D.T)  by way of various notifications had extended the time limit of issuing the notice U/s 148 of the Act up to  30th […]

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