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Section 147

Latest Articles


Tax on Property Transactions: Section 56(2)(vii)(b) & Reassessment Proceedings

Income Tax : Explore tax implications under Section 56(2)(vii)(b) and reassessment norms in property transactions. Judicial rulings emphasize e...

April 20, 2025 6354 Views 0 comment Print

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 7575 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 2700 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 2532 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 1059 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 1284 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 2955 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 7098 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 13005 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 41985 Views 2 comments Print


Latest Judiciary


Delay in filing Audit Report in Form 10B due to Covid-19 condoned: Orissa HC

Income Tax : Orissa High Court held that delay in filing Audit Report in Form 10B due to Covid-19 pandemic condoned and since it is settled law...

June 13, 2025 57 Views 0 comment Print

ITAT Quashes Reassessment: Reasons Based Solely on ADIT Information Invalid Under Sections 147/148

Income Tax : ITAT Delhi dismisses revenue appeal, upholding the quashing of reassessment proceedings against Vishal Gold & Precious Stones due ...

June 13, 2025 99 Views 0 comment Print

AWS Cloud Computing Service Receipt Not Taxable as Equipment Royalty: Delhi HC

Income Tax : The charges paid by the Assessee’s customers are for availing services, which the Assessee provides by using its proprietary equ...

June 13, 2025 42 Views 0 comment Print

Section 148 Notice quashed for Being Issued Beyond Time Limit for Income Below ₹50 Lakhs

Income Tax : Mumbai ITAT quashes reassessment for Sonali Dharmendra Mhatre, ruling it time-barred under Section 149(1)(b) as the escaped income...

June 13, 2025 96 Views 0 comment Print

Gujarat HC Quashes Income Tax Reopening for Lack of application of mind

Income Tax : Gujarat High Court sets aside notice for assessment reopening against Bharatkumar Nihalchand Shah, citing the tax officer's lack o...

June 12, 2025 120 Views 0 comment Print


Latest Notifications


ITO doesn’t have jurisdiction to issue notice to NRI: ITAT Chandigarh

Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...

April 11, 2025 4491 Views 0 comment Print

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 321 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 9570 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 4650 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 5571 Views 0 comment Print


Latest Posts in Section 147

Delay in filing Audit Report in Form 10B due to Covid-19 condoned: Orissa HC

June 13, 2025 57 Views 0 comment Print

Orissa High Court held that delay in filing Audit Report in Form 10B due to Covid-19 pandemic condoned and since it is settled law that delay in case of genuine hardship need to be allowed.

ITAT Quashes Reassessment: Reasons Based Solely on ADIT Information Invalid Under Sections 147/148

June 13, 2025 99 Views 0 comment Print

ITAT Delhi dismisses revenue appeal, upholding the quashing of reassessment proceedings against Vishal Gold & Precious Stones due to ‘borrowed satisfaction’ and lack of a ‘live link’ to the assessment year.

AWS Cloud Computing Service Receipt Not Taxable as Equipment Royalty: Delhi HC

June 13, 2025 42 Views 0 comment Print

The charges paid by the Assessee’s customers are for availing services, which the Assessee provides by using its proprietary equipment and other assets. No part of its equipment or IPRs are alienated by the Assessee in favour of its customers for their use.

Section 148 Notice quashed for Being Issued Beyond Time Limit for Income Below ₹50 Lakhs

June 13, 2025 96 Views 0 comment Print

Mumbai ITAT quashes reassessment for Sonali Dharmendra Mhatre, ruling it time-barred under Section 149(1)(b) as the escaped income was below the Rs. 50 lakh threshold.

Gujarat HC Quashes Income Tax Reopening for Lack of application of mind

June 12, 2025 120 Views 0 comment Print

Gujarat High Court sets aside notice for assessment reopening against Bharatkumar Nihalchand Shah, citing the tax officer’s lack of proper application of mind and year discrepancy.

Section 271(1)(c) Penalty notice invalid if basis not specified: Delhi HC

June 12, 2025 258 Views 0 comment Print

Delhi HC ruled in Sahara India Life Insurance Co. case that Section 271(1)(c) penalty is invalid if notice fails to specify whether it pertains to income concealment or inaccurate particulars.

No Penalty u/s 273B for Cash Loan Repayment on Lender’s Request to curb Interest Escalation

June 11, 2025 603 Views 0 comment Print

AO held that assessee had made repayment of the loan to M/s. Tata Finance Corporation in that financial year to the extent of Rs. 6,71,939 in cash against the loan taken for commercial vehicle.

SC Dismisses Revenue’s Appeal: Reopening Notice Invalid due to change of Opinion

June 11, 2025 909 Views 0 comment Print

SC upheld Gujarat HC’s decision to quash reassessment notice issued by Income Tax Department, citing lack of new material & change of opinion

Gujarat HC Quashes Income Tax Reopening Notice for Change of Opinion

June 11, 2025 183 Views 0 comment Print

The Gujarat High Court invalidated a tax reopening notice against Hemanshu Ramniklal Shah, ruling it was based on a “change of opinion” rather than new material, after the original assessment was already scrutinized.

Addition u/s 153A for completed assessments couldn’t be made without incriminating material

June 10, 2025 453 Views 0 comment Print

Since the assessments were completed in the case of assesee and there was no incriminating material found during the search in the case of the assessee, the additions made under Section 153A were unsustainable.

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