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Section 149

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Section 194S: TDS on transfer of Virtual Digital Assets (VDA)

Income Tax : The guide provides detailed rules for VDA transfers executed through exchanges, brokers, and payment gateways. It identifies who i...

June 7, 2026 15468 Views 0 comment Print

ITAT Mumbai Quashes Reassessment for Time-Barred Section 148 Notice

Income Tax : ITAT Mumbai quashes reassessment (AY 13-14, 14-15) as AO missed the Rajeev Bansal-mandated "surviving limitation." S. 149 prevails...

October 14, 2025 1311 Views 0 comment Print

Reassessment – Rajeev Bansal’s case Impact Analysis – Approving Authority

Income Tax : Analysis of the Rajeev Bansal Supreme Court ruling on reassessment approvals, clarifying complexities in Section 151 and its impac...

July 22, 2025 9312 Views 1 comment Print

Landmark Rulings on Reassessment u/s 148 – Post 2021 Amendments

Income Tax : Explore key court rulings on reassessment under Section 148 post-2021 amendments, covering procedural changes, taxpayer rights, an...

February 7, 2025 7464 Views 0 comment Print

Board of Directors: Section 149 of Companies Act, 2013

Company Law : Overview of Section 149 of the Companies Act, 2013: Board composition, women directors, resident and independent directors' roles,...

January 30, 2025 8112 Views 1 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2469 Views 0 comment Print

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 4578 Views 0 comment Print


Latest Judiciary


Section 149 Limitation Bars Section 148 Reassessment Based on Search Material: Gujarat HC

Income Tax : Gujarat HC quashed Section 148 reassessment as it was issued beyond Section 149 limitation, holding Section 152(3) applies to sear...

July 5, 2026 144 Views 0 comment Print

Section 148 Notice Issued Beyond First Proviso to Section 149 Time Limit Quashed: ITAT Mumbai

Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...

July 4, 2026 321 Views 0 comment Print

No Tax in India on German Tax Resident’s Professional Service Receipts Under DTAA: ITAT Mumbai

Income Tax : Receipts earned by a German resident individual from rendering managerial, consultancy and business development services outside I...

June 29, 2026 321 Views 0 comment Print

Section 153A Notices Upheld Despite Delay in Handing Over Seized Documents

Income Tax : The Madras High Court held that delayed transfer of seized documents under Section 132(9A) did not invalidate notices issued under...

June 27, 2026 129 Views 0 comment Print

Ahmedabad ITAT Deletes Bogus LTCG Addition; Independent Enquiry Essential

Income Tax : The Tribunal ruled that an Investigation Wing report alone cannot justify an addition under Section 68 without independent verific...

June 27, 2026 117 Views 0 comment Print


Latest Notifications


Procedure for filing and processing of Bill of Entry amendment requests

Custom Duty : Learn how to file and process Bill of Entry amendments at Jawahar Lal Nehru Custom House. Get insights on self-approval and office...

February 23, 2024 21960 Views 0 comment Print


Refund claim of excess CVD filed after one year is rejected as time barred

November 4, 2025 645 Views 0 comment Print

CESTAT Delhi held that refund claim of excess CVD paid after completion of one year from date of payment of duty as well as the date of relevant judgement is barred by limitation. Accordingly, appeal of assessee dismissed.

Reassessment held invalid as approval u/s. 151 granted in mechanical manner

November 3, 2025 1749 Views 0 comment Print

ITAT Hyderabad held that reopening of assessment is invalid in as much as the approval/ sanction under section 151 of the Income Tax Act is granted in a mechanical manner. Further, reasons for reopening are based on on-application of mind and borrowed satisfaction. Accordingly, reopening quashed and appeal allowed.

ITAT Delhi Quashes Reassessment for AY 2015-16 as Notice Issued Beyond Limitation Period

November 2, 2025 1023 Views 0 comment Print

The ITAT Delhi allowed the appeal of Sunita Salhotra, quashing the Section 148 notice for AY 2015-16 as barred by the statutory limitation period that expired on March 31, 2022. The Tribunal relied on the Revenue’s concession in the Supreme Court’s Rajiv Bansal case regarding notices issued for this AY on or after April 1, 2021.

Approval from PCIT Instead of PCCIT Invalidates Section 148 Notice: ITAT Pune

November 2, 2025 1080 Views 0 comment Print

ITAT Pune annulled reassessment proceedings, holding that approval by PCIT instead of PCCIT for notices issued after three years was contrary to Section 151.

WhatsApp Chats as Evidence: ITAT Upholds ₹9 Lakh Addition on Unrebutted Digital Record

October 31, 2025 1305 Views 0 comment Print

ITAT Delhi ruled that WhatsApp chats recovered during a search, if corroborated by context and left unrebutted by the assessee, create a statutory presumption of correctness under Section 292C, leading to a sustained addition of ₹9 lakh as unexplained money. The Tribunal also directed the allowance of an 80TTA deduction claim for the abated assessment year (AY 2018-19).

ITAT Delhi Quashed Reassessments for Wrong Reasons, Time-Bar & Invalid Sanction

October 31, 2025 669 Views 0 comment Print

The ITAT Delhi quashed reassessment orders for three assessment years (AY 2011-12, 2015-16, 2016-17) based on fundamental legal flaws. The ruling confirms that reassessments are invalid if initiated on wrong or substituted reasons, if they are time-barred (following the Supreme Court’s concession in the Rajeev Bansal case), or if they proceed without valid statutory sanction from the competent authority.

Reopening Barred by Limitation: ITAT Quashes 148 Notice for AY 2015-16 Post-TOLA

October 31, 2025 1332 Views 0 comment Print

ITAT Kolkata quashed the reopening assessment for AY 2015-16, ruling the Section 148 notice issued on 31.07.2022 was time-barred. This decision strictly follows the Rajeev Bansal (SC) judgment, which held that the TOLA extension for reopening notices did not apply to AY 2015-16 beyond 31.03.2021.

Reassessment Notices beyond Limitation – ITAT Delhi Quashes Proceedings

October 30, 2025 435 Views 0 comment Print

ITAT Delhi quashed reassessment proceedings for AY 2013-14 and 2015-16, ruling that notices issued after the extended final deadline of June 24, 2022, were time-barred under Section 149, following the Rajeev Bansal ruling.

Search Assessment Barred: Limitation Period Starts When AO Gets Seized Papers

October 29, 2025 756 Views 0 comment Print

ITAT Delhi dismissed the Revenue’s appeal, ruling that the assessment under Section 153C was time-barred because the block period must be calculated from the date the Assessing Officer (AO) of the non-searched person received the seized material. The ruling confirms that the date of the original search is irrelevant for non-searched persons.

Reassessment based on direction of CIT(A) post period prescribed u/s. 149 cannot be sustained

October 28, 2025 381 Views 0 comment Print

Gujarat High Court held that reopening of assessment based on direction of CIT(A) cannot be sustained since the period of limitation prescribed under section 149(1) of the Income Tax Act has expired. Accordingly, reassessment notice u/s. 148 quashed and petition is allowed.

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