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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 7344 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 2136 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 1482 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 966 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1596 Views 0 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 1200 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 2712 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 7065 Views 0 comment Print

Indiscriminate Income Tax notices without allowing reasonable time

Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...

March 20, 2022 12981 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 41919 Views 2 comments Print


Latest Judiciary


Correspondence with CA Does Not Justify Notices to Deceased Person: Bombay HC

Income Tax : Bombay HC quashes tax notices issued to deceased Amjad Ahmed Shaikh. Court emphasizes notices to dead are void, allowing fresh act...

April 10, 2025 975 Views 0 comment Print

Section 151A: JAO Lacks Jurisdiction to Issue Section 148 Income Tax Notices

Income Tax : Rajasthan High Court held that, in terms of section 151A of the Income Tax Act, Jurisdictional Assessing Officer [JAO] doesn’t h...

April 9, 2025 1269 Views 0 comment Print

Single Satisfaction Note under Section 153C for Multiple Years is invalid: Karnataka HC

Income Tax : Karnataka HC rules single tax 'satisfaction note' invalid for multiple years. Separate notes required under Section 153C, impactin...

April 8, 2025 243 Views 0 comment Print

Revision u/s. 263 based on audit objection impermissible: ITAT Chandigarh

Income Tax : ITAT Chandigarh held that initiation of revisionary proceedings under section 263 of the Income Tax Act on the basis of audit obje...

April 8, 2025 315 Views 0 comment Print

ITAT Deletes ₹8.01 Crore Section 68 Addition on Penny Stock Transactions

Income Tax : ITAT Mumbai allows Sejal Jignesh Shah’s appeal against tax additions under Section 68, rejecting AO's reliance on investigation ...

April 8, 2025 4428 Views 0 comment Print


Latest Notifications


Central Government Rescinds 6 Central Excise Notifications issued in 2022

Excise Duty : Notification No. 29/2024-Central Excise rescinds six 2022 excise notifications in the public interest, effective immediately. Deta...

December 2, 2024 282 Views 0 comment Print

Instructions to AO’s for initiating section 147 proceedings in I.T. e-Verification cases

Income Tax : Learn how to initiate proceedings under section 147 of the IT Act in e-Verification cases. Detailed instructions for Assessing Off...

March 19, 2024 9459 Views 0 comment Print

Instructions to AO’s for initiating Section 147 proceedings in e-Verification cases

Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...

March 1, 2024 4419 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 5526 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 3033 Views 0 comment Print


Latest Posts in Section 147

Correspondence with CA Does Not Justify Notices to Deceased Person: Bombay HC

April 10, 2025 975 Views 0 comment Print

Bombay HC quashes tax notices issued to deceased Amjad Ahmed Shaikh. Court emphasizes notices to dead are void, allowing fresh action. The court dismissed revenue’s explanation regarding correspondence with the chartered accountant, stating it did not justify issuing notices to a deceased person.

Section 151A: JAO Lacks Jurisdiction to Issue Section 148 Income Tax Notices

April 9, 2025 1269 Views 0 comment Print

Rajasthan High Court held that, in terms of section 151A of the Income Tax Act, Jurisdictional Assessing Officer [JAO] doesn’t have jurisdiction to issue notices under section 148 of the Income Tax Act. Accordingly, notices u/s. 148 are liable to be quashed.

Single Satisfaction Note under Section 153C for Multiple Years is invalid: Karnataka HC

April 8, 2025 243 Views 0 comment Print

Karnataka HC rules single tax ‘satisfaction note’ invalid for multiple years. Separate notes required under Section 153C, impacting tax assessments.

Revision u/s. 263 based on audit objection impermissible: ITAT Chandigarh

April 8, 2025 315 Views 0 comment Print

ITAT Chandigarh held that initiation of revisionary proceedings under section 263 of the Income Tax Act on the basis of audit objection is not permissible. Accordingly, order of PCIT quashed and appeal of assessee allowed.

ITAT Deletes ₹8.01 Crore Section 68 Addition on Penny Stock Transactions

April 8, 2025 4428 Views 0 comment Print

ITAT Mumbai allows Sejal Jignesh Shah’s appeal against tax additions under Section 68, rejecting AO’s reliance on investigation reports in a penny stock case.

ITAT Allows Appeal Delay, Directs Fresh Adjudication by AO Following SC Guidelines

April 8, 2025 2379 Views 0 comment Print

ITAT Pune condones delay in appeal by Vaibhav Surve, remands case for reassessment of capital gains on land sale under Section 50C.

ITAT Quashes Section 147 Proceedings for Incorrect Presumption of Facts

April 8, 2025 396 Views 0 comment Print

ITAT Ahmedabad quashes reassessment against Komal Ketan Shah, citing lack of evidence and incorrect factual basis under Section 147 for AY 2016–17.

Re-opening u/s. 147 quashed as not based on tangible material: Madras HC

April 7, 2025 708 Views 0 comment Print

Madras High Court held that re-opening of assessment u/s. 147 must be based on some tangible material without such tangible material, re-opening is merely inspired from change of opinion and hence the same is liable to be quashed.

Change of Opinion without New Material: ITAT Raipur Quashes Reassessment

April 5, 2025 186 Views 0 comment Print

ITAT Raipur quashes Sec 147 reassessment in ITO Vs Bishambhar Dayal Agrawal. Held reopening based on change of opinion, not new material, is invalid. Cites Kelvinator.

Addition of income which has escaped assessment sustained even if not specifically mentioned in re-opening order

April 5, 2025 132 Views 0 comment Print

Guwahati High Court held that AO can make addition of any other income which has escaped assessment but discovered during re-opening process even if the same is not specifically mentioned in re-opening order.

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