Sponsored
    Follow Us:

Section 147

Latest Articles


Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 6573 Views 0 comment Print

Recent Judgements of Supreme Court on Income Tax Issues

Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....

January 22, 2024 8358 Views 1 comment Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...

December 10, 2023 19590 Views 7 comments Print


Latest News


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 6936 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 12900 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 41382 Views 2 comments Print

Notices for assessment/reassessment of income of old cases

Income Tax : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...

August 3, 2018 1893 Views 0 comment Print

No Reopening of Assessment to be made on Audit Objections: Committee Recommends

Income Tax : One of the key sources of dispute is the existing arrangement for follow up on audit objections by Internal Audit Party and the Re...

January 20, 2016 6657 Views 0 comment Print


Latest Judiciary


Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 63 Views 0 comment Print

Reassessment cannot be based solely on reevaluating existing facts without new substantive material

Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...

July 17, 2024 60 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 126 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 261 Views 0 comment Print

Non-Filing of GST Return by Supplier – Assessment Reopening Validity- ITAT Mumbai Order

Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...

July 17, 2024 738 Views 0 comment Print


Latest Notifications


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 8571 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 3063 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 5337 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 2934 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 14292 Views 1 comment Print


Income escaping assessment | Action to be taken | AY 2013-14 to 2017-18

March 9, 2021 19980 Views 0 comment Print

Which functionality is to be used for uploading the information in respect of cases where the income escaping assessment pertains to AYs 2013-14 to 2017-18 as mentioned in Para 2(a) of the aforementioned directions issued vide F.No.414/132/2018-IT(Inv.I)(Part I) dated 5th March, 2021?

Instructions for issue of Section 148 notice for Reassessment/Reopening

March 4, 2021 47214 Views 2 comments Print

CBDT directs that following categories of cases be considered as ‘potential cases’ for taking action u/s 148 of Act by 31.03.2021 for the A.Y 2013-14 to A.Y 2017-18 by Jurisdictional Assessing Officer

Addition for unexplained cash deposit by CIT(A) justified -ITAT Delhi

March 4, 2021 3789 Views 0 comment Print

Shri Praveen Garg Vs ITO  (ITAT Delhi) There is no dispute with regard to the legal proposition that the First Appellate Authority cannot consider new source of income. However, in the present case the A.O. reopened the assessment because it was found that there were cash deposits in several Bank accounts of the assessee which […]

HC quashes Section 148 Notice issued without prior administrative approval of PCIT

March 4, 2021 2565 Views 0 comment Print

According to Mr. Mahna, the administrative approval of Principal Chief Commissioner, Income Tax was obtained by the Assistant Commissioner, Income Tax only on 30.03.2018, i.e., after the issuance of the notice under Section 148 of the Act.

No Reopening On Borrowed Satisfaction Without Bringing Tangible Material on Record

February 23, 2021 1842 Views 0 comment Print

Luxe Trading And Holding (India) Pvt. Ltd. Vs ITO (ITAT Delhi) From a perusal of the reasons, it is seen that the notice u/s. 148 of the Act has been issued mechanically without application of mind and the satisfaction by the Assessing Officer is only the borrowed satisfaction of the Investigation Wing. The Assessing Officer, […]

No Change of Opinion if facts related to deemed consideration U/s. 50C been overlooked

February 19, 2021 981 Views 0 comment Print

Rakesh Ambalal Patel Vs ITO (ITAT Ahmedabad) We have perused the assessment order and the order of the CIT(A) as well as the materials placed on record and referred to in terms of Rule 18(6) of the Income Tax (Appellate Tribunal) Rules, 1963. On perusal, we observe that at the time of original assessment proceedings, […]

No Reopening on Borrowed Satisfaction when view was already taken by AO

February 19, 2021 1506 Views 0 comment Print

Alliance Filaments Ltd Vs ACIT (Gujarat High Court) A plain reading of the reasons recorded revels that the Assessing Officer has solely relied on the information received from the Investigation Wing- Surat. We are of the view that, the Assessing Officer has not applied his independent mind while recording the reasons that the income has […]

Reopening of assessment invalid if based on “change of opinion”

February 18, 2021 1107 Views 0 comment Print

We are of the view that the AO has re-opened the assessment on mere change of opinion, because it is the assessing officer who took a different view at the time of reopening of assessment, i.e., he has entertained an opinion that the family members should have transferred the gold to the assessee firm and then the assessee firm should have held the gold on its own account.

Section 147: AO must act based on ‘reasons to believe’ & not on ‘reasons to suspect’

February 12, 2021 4617 Views 0 comment Print

Kasapu Ramesh Babu Vs ITO (ITAT Visakhapatnam) Assessing Officer has to act on the basis of “reasons to believe” and not on “reasons to suspect”. In the instant case, the initiation of proceedings u/s 147 of the Act are based upon no evidence and/or un-corroborative material. The Assessing Officer further failed to establish the nexus […]

Mere Vague Air Information of Cash Deposit Not Sufficient to believe Escapement of Income

February 10, 2021 3162 Views 0 comment Print

Harmeet Singh Vs ITO (ITAT Delhi) At the time of hearing, Ld. Counsel of the assessee has only argued the legal ground and stated that the reopening action of the AO and confirmation thereof by the Ld. CIT(A) is in violation of mandatory jurisdictional conditions stipulated under the Act. It was further stated that the […]

Sponsored
Search Post by Date
July 2024
M T W T F S S
1234567
891011121314
15161718192021
22232425262728
293031