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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 87 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


Section 148 on Dead Person: ITAT Quashes Reopening & Entire Assessment as Void

December 4, 2025 402 Views 0 comment Print

Court held that an income tax assessment issued after the assessee’s death is null and void, emphasizing the legal heir’s right to contest the order.

Delay Condoned & Ex-Parte NFAC Order Quashed: ITAT Sends Appeal Back

December 4, 2025 345 Views 0 comment Print

ITAT condoned a 23-day delay and quashed the ex-parte order of NFAC, sending the appeal back for fresh adjudication. Appeals must be decided on merits even if delayed, prioritizing fairness.

Notice Issued to Dead Person: ITAT Sends 148 Jurisdiction Issue Back to CIT(A)

December 4, 2025 255 Views 0 comment Print

ITAT held that the reassessment notice issued after the assessee’s death raised jurisdictional issues. Legal grounds like issuance to a deceased must be adjudicated before proceeding with assessments.

ITAT Orders Fresh Hearing After Non-Speaking CIT(A) Order in Reopening Case

December 4, 2025 282 Views 0 comment Print

The order was remanded after ITAT found the CIT(A) overlooked core issues including validity of belated 148 return, applicability of 153C, and cross-examination rights.

Tribunal Deletes ₹2.14 Crore Addition Due to Invalid Pre-Notification NFAC Action

December 4, 2025 1017 Views 0 comment Print

ITAT Kolkata quashed a reassessment order, holding that NFAC had no jurisdiction before the formal notification of Section 151A. The ₹2.14 crore addition was deleted, highlighting that faceless assessments cannot be retroactively enforced.

Section 148 Notice Without Jurisdiction Renders 263 Unsustainable

December 3, 2025 636 Views 0 comment Print

ITAT Ahmedabad held that a section 263 revision cannot proceed if the AO issuing section 148 notice lacks territorial jurisdiction, emphasizing the need to first decide jurisdictional validity.

193-Day Delay Condoned: ITAT Says Don’t Deny Merits to Rural Assessee

December 3, 2025 390 Views 0 comment Print

The Tribunal allowed a 193-day delayed appeal, emphasizing that non-deliberate delay should not bar hearing on merits. The assessee can now present his case and have the appeal adjudicated substantively.

ITAT Quashes ₹1 Cr Addition Under Section 148 on Penny Stock LTCG

December 3, 2025 432 Views 0 comment Print

Assessee proved long-term capital gains of ₹1 crore from Mishkafin Finance shares via broker notes, bank statements, and STT-paid transactions. Addition under section 69A was deleted due to lack of evidence.

CIT(A) Cannot Hide Behind PCIT’s 263 Order – Independent Application of Mind Mandatory

December 3, 2025 345 Views 0 comment Print

ITAT Jabalpur held that CIT(A) cannot blindly follow PCIT directions under section 263. Appellate authorities must independently consider evidence and objections before confirming additions.

No Inquiry, No Jurisdiction: PCIT Revision Under Section 263 Invalid

December 3, 2025 318 Views 0 comment Print

ITAT held that Section 263 requires the PCIT to conduct independent inquiry before declaring an order erroneous. Since the PCIT relied only on assumptions of inadequate inquiry, the revision was invalid.

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