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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 19596 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 72 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 66 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 132 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 273 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 786 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 3066 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 14295 Views 1 comment Print


Section 148 Notice to Legal heirs after expiry of limitation period is invalid

August 27, 2020 9066 Views 0 comment Print

Sh. Shambhu Dayal, Ravi Dutt, Gori Shankar Rajesh Rohit L/h Late Sh. Jhabar Mal (ITAT Jaipur) The undisputed facts are that the assessee, Shri Jhabar Mal Kumawat had expired on 10.10.2015 as noted by the AO in the assessment order. Thereafter, the reasons for reopening the assessment u/s 147 were recorded and after seeking approval […]

Second Re-Assessment Notice Issued against Johnson & Johnson is Rejected by ITAT

August 25, 2020 765 Views 0 comment Print

The issue under consideration is whether the re-opening of assessment u/s 147 of the Act is justified in law?

No addition for other items if addition for reopening of reassessment not survives

August 19, 2020 1065 Views 0 comment Print

Naresh Kumar Garg Vs ACIT (ITAT Delhi) When the grounds for reopening the reassessment do not exist any longer and no additions were ultimately made on that account, the addition in respect of the other items, which were not part of the ‘ reasons to believe’cannot be made. ITAT states that it is evident that […]

Reopening of Assessment for Mere Change of Opinion is unjustified

August 12, 2020 1884 Views 0 comment Print

Whether the Tribunal was justified in holding that the reopening of assessment was a result of mere change of opinion, even when there is no opinion formed or expressed by the Assessing Officer on this issue in the original assessment?

Onus on Revenue to prove Assessee Paid Donation to College in Cash

August 12, 2020 921 Views 0 comment Print

The issue under consideration is whether the addition made by AO merely based on the statement recorded under section 132(4) of the I.T. Act is justified in law?

Assessment cannot be Reopened if Assessee disclosed fully & Truly All Material Facts during Original Assessment

August 12, 2020 1575 Views 0 comment Print

The issue under consideration is whether the AO is correct in re-opening of the assessment under section 147 even though the assessee has disclose fully and truly all the material facts during original assessment?

Reassessment not sustainable when reasons for initiation of proceedings Seized to Survive

August 11, 2020 951 Views 0 comment Print

Aince the AO has accepted the returned income for which reasons were recorded, therefore, for making any other addition, he should have issued fresh notice

Assessment reopening based on Wrong Appreciation of Facts is unsustainable

August 10, 2020 1347 Views 0 comment Print

The issue under consideration is whether the re-opening of assessment u/s 147 on the basis of wrong appreciation of facts can be sustained in law?

Issues in Respect of Reopening of Assessment

August 10, 2020 4137 Views 0 comment Print

Mr. Jay Kishor Mishra, IRS (IT: 1993) CIT (DR)(ITAT)-4, Delhi jkmishrairs@gmail.com Mr. Jay Kishor Mishra is an officer of the 1993 batch of the Indian Revenue Service. He is a Graduate in Economics and Post Graduate in Sanskrit. He is an LLB and also holds Post Graduate Diploma in Management. Ms Sushama Singh, IRS (IT: […]

No TDS on payments to NRI for Purchase of Raw Materials

July 31, 2020 3456 Views 0 comment Print

The issue under consideration is whether the provisions of deduction of tax at source (TDS) would be applicable in case of payments made to non-resident Indian for the purchase of raw materials?

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