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Section 147

Latest Articles


Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 507 Views 0 comment Print

Sections 147 & 148 of Income-Tax Act: Reassessment From ‘Reason to Believe’ to ‘Information’

Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...

February 28, 2026 873 Views 0 comment Print

Jurisdiction for Reassessment Notices Clarified to End Faceless AO Disputes

Income Tax : The Finance Bill, 2026 clarifies who can issue notices under sections 148 and 148A. It confirms that only jurisdictional Assessing...

February 2, 2026 2841 Views 0 comment Print

Can Penalty be Levied on Delayed Annual GST Return?

Goods and Services Tax : The court held that once late fee is imposed for delayed annual return filing, a further general penalty is not permissible. Secti...

January 20, 2026 18258 Views 2 comments Print

Reassessment Quashed as Limitation Ran From Original Assessment, Not Revision

Income Tax : The issue was whether an assessment could be reopened after four years. The Court held that full disclosure by the taxpayer barred...

January 8, 2026 423 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 2193 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 4314 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 7458 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 13332 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 42774 Views 2 comments Print


Latest Judiciary


Section 68 Additions: Favourable Remand Report Shields Assessee

Income Tax : The issue was deletion of additions on unsecured loans treated as unexplained cash credits. The tribunal upheld deletion, holding ...

May 2, 2026 57 Views 0 comment Print

Delay Condoned with Cost: ITAT Grants Fresh Chance, Slams Non-Compliance

Income Tax : The issue involved dismissal of appeal due to delay and non-appearance. The tribunal condoned the delay citing medical reasons and...

May 2, 2026 96 Views 0 comment Print

Reassessment After 4 Years Quashed as No Failure to Disclose Material Facts: Bombay HC

Income Tax : The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening inval...

May 2, 2026 66 Views 0 comment Print

Reassessment Quashed for Wrong Sanction: ITAT Bangalore Strikes Down 147 Order for Breach of Section 151

Income Tax : The issue was whether reassessment notice issued without approval from the correct authority is valid. The tribunal held it invali...

May 2, 2026 84 Views 0 comment Print

Reassessment Notice Time-Barred as Issued Beyond Limitation Period: Karnataka HC

Income Tax : The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after t...

May 1, 2026 447 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 5742 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 813 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 10272 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 5784 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 5880 Views 0 comment Print


ITAT Rajkot: Mechanical Approval Invalid – Reopening U/s 148 Quashed

April 14, 2026 162 Views 0 comment Print

The issue was validity of reopening based on approval lacking proper application of mind. The Tribunal held such mechanical approval invalid, rendering the reassessment void.

ITAT Ahmedabad: No Penalty for Mere Wrong Claim – U/s 271(1)(c) Deleted

April 14, 2026 138 Views 0 comment Print

The issue was whether incorrect tax treatment amounts to concealment. The Tribunal held that mere wrong classification in books does not attract penalty under Section 271(1)(c).

ITAT Mumbai: Section 68 Addition Deleted – Mere Suspicion & Third-Party Info Not Enough

April 14, 2026 168 Views 0 comment Print

The issue was whether addition can be made based on third-party investigation findings. The Tribunal held that without direct incriminating evidence, such addition is unsustainable, emphasizing the need for nexus.

ITAT Delhi: No Proper Service of U/s 148 Notice – Entire Reassessment Quashed

April 14, 2026 186 Views 0 comment Print

The issue was whether reassessment is valid without proper service of notice. The Tribunal held that absence of valid service makes the entire reassessment void and unsustainable.

ITAT Mumbai: No Penalty U/s 271(1)(c) on Estimated Bogus Purchase Additions

April 13, 2026 387 Views 0 comment Print

The Tribunal held that penalty under Section 271(1)(c) cannot be imposed when additions are made on an estimated basis. It upheld deletion of penalty, emphasizing absence of concrete evidence of concealment.

ITAT Mumbai: Sec 54 Claim Cannot Be Denied Merely for No Original Return-Allowed in Reassessment

April 13, 2026 594 Views 0 comment Print

The Tribunal clarified that filing of original return is not mandatory for claiming exemption under Section 54. It directed verification of conditions and allowed relief if eligibility is established.

Reassessment Invalid Due to Change of Opinion on Same Facts: ITAT Mumbai

April 13, 2026 276 Views 0 comment Print

The Tribunal held that reopening an assessment on identical material already examined is invalid. It ruled that reassessment cannot be used to revisit concluded issues without fresh evidence.

ITAT Mumbai Quashes Reopening: Approval by Wrong Authority u/s 151 Makes Entire Reassessment Void

April 13, 2026 243 Views 0 comment Print

The case addresses whether reassessment is valid when approval is granted by the wrong authority. ITAT held that sanction under Section 151 is jurisdictional and must be from the correct authority. The entire reassessment was quashed for non-compliance.

ITAT Pune: No Penalty When Mistake Attributable to Tax Consultant – Bona Fide Conduct Accepted

April 13, 2026 780 Views 0 comment Print

ITAT held that penalty cannot be imposed where incorrect return was due to consultant’s misconduct. The ruling highlights that bona fide mistakes with voluntary tax payment negate penalty.

ITAT Mumbai: Reopening Invalid on Change of Opinion-No Fresh Material, Assessment Quashed

April 13, 2026 183 Views 0 comment Print

ITAT held reassessment invalid as it was based on already examined facts without fresh material. The ruling reinforces that reopening on mere change of opinion is not permissible.

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