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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 2844 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 90 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 111 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 99 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 93 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 453 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 5745 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


Revenue’s Section 68 Challenge Rejected on Evidence and Repayment

December 5, 2025 666 Views 0 comment Print

The assessee furnished PANs, bank statements, and confirmations proving the genuineness of share capital and loan transactions, leading to dismissal of the Revenue appeal. Both CIT(A) and Tribunal confirmed that repayment and identity verification are sufficient. This reinforces legal certainty in documented transactions under Section 68.

Section 68 Addition Quashed for Violating Principles of Natural Justice

December 5, 2025 435 Views 0 comment Print

The Tribunal held that the loan could not be treated as unexplained when the assessee had furnished complete documentary evidence. The authorities failed to conduct further inquiry or rebut the lender’s confirmation. The ruling emphasizes that additions under Section 68 cannot be made solely on suspicion.

Format Matters: ITAT Says Invalid 143(2) Notice Vitiates Whole Proceedings

December 5, 2025 708 Views 0 comment Print

The Tribunal found that the notice did not indicate whether scrutiny was limited or complete, contrary to CBDT directives. This omission made the notice invalid and rendered the assessment unsustainable. The decision reinforces the necessity of clarity and compliance in scrutiny notices.

Uncorroborated 132(4) Statement Can’t Tax a Genuine Donation

December 5, 2025 435 Views 0 comment Print

ITAT Mumbai held that donations to registered trusts cannot be taxed under Section 69C solely based on third-party statements without supporting evidence.

Capital Gain Proven with Full Documentation; Section 69A/69C Additions Deleted

December 5, 2025 378 Views 0 comment Print

The assessee’s capital-gain computation and share-transaction trail matched disclosed data. ITAT held the AO’s conclusion to be unsupported and dismissed Revenue’s appeal.

No Cash Trail and Retracted 132(4) Statements – Section 68 Addition Deleted

December 5, 2025 588 Views 0 comment Print

ITAT held that once investments were accepted in prior assessments, their sale proceeds cannot be treated as unexplained income. The ruling confirms that Section 68 cannot be invoked without fresh incriminating evidence.

Severe Handicap, Wrong Advice Ex-Parte Orders – ITAT Restores Cash-Deposit Case to AO

December 5, 2025 303 Views 0 comment Print

The Tribunal allowed the appeal partly due to the assessee’s 60% handicap, emphasizing that delay in filing was not deliberate. The case was remanded for merit-based adjudication, ensuring fairness. Key takeaway: disabilities and procedural lapses can justify condoning appeal delays.

Communication Gap in Faceless Regime: ITAT Sends Matter Back to CIT(A)

December 5, 2025 291 Views 0 comment Print

Tribunal held that the CIT(A)’s ex-parte order violated natural justice. The matter was remanded for a fresh decision with proper opportunity to the assessee.

ITAT Pune: ₹1.62 Cr u/s 68 Deleted — No “Source of Source” Needed Pre-01.04.2023

December 5, 2025 1770 Views 0 comment Print

Explains how ITAT Pune held that unsecured loans prior to 01.04.2023 do not require proving the lender’s source of funds, leading to deletion of a ₹1.62 crore addition.

Escapement Below ₹50L: ITAT Quashes 148 Notice Issued After 3 Years

December 4, 2025 1083 Views 0 comment Print

ITAT Delhi held that a reassessment notice issued three years after the relevant AY is invalid if the alleged escaped income is below ₹50 lakh, reinforcing the statutory threshold protection.

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