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Section 147

Latest Articles


FAQs on Assessments under Income-tax Law

Income Tax : Learn about various types of income tax assessments under Sections 143, 144, and 147, their procedures, time limits, and taxpayer ...

November 4, 2025 90057 Views 7 comments Print

FAQs on Maintenance of books of accounts under Income Tax Act, 1961

Income Tax : Section 44AA mandates books for professionals and businesses exceeding income thresholds. Details presumptive tax rules, required ...

October 31, 2025 3435 Views 0 comment Print

Reopening on Borrowed Belief from ACB Quashed – Tribunal holds 147 invalid & 263 unsustainable

Income Tax : Ahmedabad ITAT quashes reassessments based on ACB report, ruling the AO lacked independent "reason to believe" and only used borro...

October 26, 2025 468 Views 0 comment Print

Time limit for issuing different income-tax notices & completion of assessment

Income Tax : Summary of statutory deadlines for issuing income tax notices (Sec 143, 147) and completing assessments, reassessments, and appeal...

October 17, 2025 22749 Views 0 comment Print

Rectification, Assessment and Appeal under Income Act, 1961

Income Tax : Understand the three core processes of Indian Income Tax: Rectification of mistakes (Sec 154), the four types of Assessment (Summa...

October 17, 2025 9213 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 1557 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 3297 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 7224 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 13101 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 42231 Views 2 comments Print


Latest Judiciary


No Defect in Books, No Section 68- When Books Are Clean, Additions Can’t Stand

Income Tax : Tribunal held that incremental cash deposits in bank accounts cannot be treated as unexplained under Section 68 without concrete e...

November 9, 2025 42 Views 0 comment Print

Capital Gains on Development Rights Taxable to Members, Not Society: ITAT Mumbai

Income Tax : ITAT Mumbai held that consideration from a redevelopment agreement is taxable in hands of individual members, not co-operative hou...

November 9, 2025 48 Views 0 comment Print

ITAT Ahmedabad Remands Case for Proper Adjudication of URD Cash Transactions

Income Tax : The ITAT Ahmedabad remanded the case of Harshang Kaushikkumar Rami vs ITO to the Assessing Officer for fresh verification of Rs. 5...

November 9, 2025 60 Views 0 comment Print

No Coercive Recovery During Pendency of Appeal in Reassessment Case: Madras HC

Income Tax : The Madras High Court stayed recovery for 90 days, allowing Faiz Wahab time to file a stay application after the sale advance refu...

November 8, 2025 183 Views 0 comment Print

ITAT Deletes ₹2.5 Cr Loan Addition After AO Failed to Rebut Lender’s Creditworthiness

Income Tax : The ITAT Kolkata upheld the deletion of a ₹2.5 crore addition under Section 68, ruling that the assessee provided full documenta...

November 7, 2025 261 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 4980 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 423 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 9762 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 5043 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 5667 Views 0 comment Print


Latest Posts in Section 147

No Defect in Books, No Section 68- When Books Are Clean, Additions Can’t Stand

November 9, 2025 42 Views 0 comment Print

Tribunal held that incremental cash deposits in bank accounts cannot be treated as unexplained under Section 68 without concrete evidence. Addition of Rs. 40.32 lakh was deleted.

Capital Gains on Development Rights Taxable to Members, Not Society: ITAT Mumbai

November 9, 2025 48 Views 0 comment Print

ITAT Mumbai held that consideration from a redevelopment agreement is taxable in hands of individual members, not co-operative housing society. Tribunal upheld CIT(A)’s deletion of ₹4.97 crore addition, confirming that society acted merely as a representative.

ITAT Ahmedabad Remands Case for Proper Adjudication of URD Cash Transactions

November 9, 2025 60 Views 0 comment Print

The ITAT Ahmedabad remanded the case of Harshang Kaushikkumar Rami vs ITO to the Assessing Officer for fresh verification of Rs. 5 crore cash deposits treated as unexplained income.

No Coercive Recovery During Pendency of Appeal in Reassessment Case: Madras HC

November 8, 2025 183 Views 0 comment Print

The Madras High Court stayed recovery for 90 days, allowing Faiz Wahab time to file a stay application after the sale advance refund was taxed as unexplained income.

ITAT Deletes ₹2.5 Cr Loan Addition After AO Failed to Rebut Lender’s Creditworthiness

November 7, 2025 261 Views 0 comment Print

The ITAT Kolkata upheld the deletion of a ₹2.5 crore addition under Section 68, ruling that the assessee provided full documentary proof of the loan’s identity, creditworthiness, and genuineness. The Tribunal emphasized that once the primary onus is discharged, the AO must conduct an independent inquiry rather than relying on an unverified Investigation Wing report.

Addition Based Solely on Third-Party Statement Without Cross-Examination Quashed

November 7, 2025 405 Views 0 comment Print

ITAT Ahmedabad held that an addition under Section 69 based only on an untested third-party statement, without cross-examination, violates natural justice. The ₹60 lakh on-money allegation was deleted.

Reassessment on Wound-Up Foreign FPI Held Void: ITAT Quashes ₹456 Cr Addition

November 7, 2025 93 Views 0 comment Print

ITAT Delhi ruled that a reassessment notice served under Section 148 on a foreign FPI (Singapore company) after its formal dissolution is void ab initio. This decision confirms that proceedings against a non-existent entity, even if served shortly after winding up, are invalid and cannot be cured by Section 292B.

ITAT Ahmedabad Restores Bogus LTCG Addition on Penny Stock ‘Safal Herbs’

November 7, 2025 144 Views 0 comment Print

The ITAT Ahmedabad reversed the CIT(A)’s deletion, upholding the addition of ₹6.73 lakh under Section 69A for bogus Long-Term Capital Gain from Safal Herbs Ltd. shares. The Tribunal ruled that the sudden investment in the obscure scrip, coupled with an unreasonable price rise, defied commercial logic and was an accommodation entry.

Dead Firm, Live Notice: ITAT Rajkot Quashes Reassessment Against Non-Existent Entity

November 7, 2025 96 Views 0 comment Print

The ITAT Rajkot set aside reassessment proceedings initiated under Section 148 against a firm that had previously converted into a private limited company. The Tribunal held that a notice issued in the name of a non-existent entity strikes at the root of jurisdiction and renders the entire assessment void ab initio.

Reassessment u/s. 147 based solely on change of opinion is impermissible

November 7, 2025 120 Views 0 comment Print

ITAT Mumbai held that reopening of assessment under section 147 of the Income Tax Act impermissible since based solely on change of opinion without any new tangible material. Further, even on merits royalty payment represents a legitimate business expenditure allowable u/s. 37(1).

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