High Court · Madras2024§148
Reassessment & Section 148 Support for CA Firms
A 148A(b) gives your client seven days, and the information annexure raises more questions than it answers.
Post-2021 reassessment is a jurisdictional minefield (limitation, sanction authority, the faceless mandate) and every defect is a ground, if someone spots it in time.
8 retired officers of the Income Tax Department259+ years cumulative service in the DepartmentWhite-label · NDA-backed · Your letterhead
What lands on your desk
- 148A(b) replies within the statutory window
- Objections to 148A(d) orders and reopening notices
- Sanction challenges: §151 authority, application of mind, elapsed-period mapping
- JAO-vs-FAO jurisdictional analysis on every file
- Writ-support briefs for counsel where the threshold challenge belongs in the High Court
Same-week drafts against 148A(b) windows; jurisdiction memo in 48 hours.
Process
Send the notice bundle
148A(b) notice, annexed information, and the client's return history.
Jurisdiction check first
Limitation, sanction authority and the faceless route, mapped before any merits work.
Drafts on your letterhead
Reply, objections or writ-support brief in your format.
You file and represent
We never appear; the strategy note stays between us and you.
The pilot
Send us one scrutiny file.
Fixed fee, agreed before we start. A retired officer reads the file and returns a written assessment within 48 hours: exposure, grounds, and what the reply must contain. Under NDA, on your letterhead, before any retainer conversation.
Recent rulings this desk works from
Reassessment · §148/148A hub →High Court · Bombay2024§148A(b) · §148A(d)
Bombay High Court on §148A: a non-contributing joint owner cannot be reopened for the spouse's purchase
High Court · Bombay2024§148
Patanjali Foods Ltd · Bombay High Court on §148: no reopening for periods before an NCLT-approved resolution plan
ITAT · Kolkata Bench2024§148
R.S. Darshan Singh Motor Car Finance v. ITO · ITAT Kolkata on §148: unverified source information voids the notice
Questions CA firms ask first
The notice window is under a week. Can you still take the file?
Yes. 148A(b) timelines are the desk's normal working condition. Send the bundle on WhatsApp and the 48-hour assessment starts the same day.
What makes your reassessment review different from ours?
The people doing it spent careers issuing and sanctioning these very notices. They check the reopening the way the Department's own review would (limitation, authority, mechanism) before touching the merits.
Is this white-label too?
Fully. Letterhead, NDA, no client contact: the same confidentiality terms as every desk. The white-label page sets out the policy in writing.