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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 5763 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1665 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 921 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2496 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


Reassessment notice issued u/s. 148 beyond six years is time barred: ITAT Mumbai

Income Tax : ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. A...

March 10, 2025 69 Views 0 comment Print

ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...

March 9, 2025 108 Views 0 comment Print

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....

March 9, 2025 111 Views 0 comment Print

ITAT Surat Directs Re-examination of Tax on Gift from HUF

Income Tax : ITAT Surat remands case to CIT(A) for fresh adjudication on HUF gift taxability under Section 56(2)(vii) of the Income Tax Act, ci...

March 9, 2025 207 Views 0 comment Print

Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 252 Views 0 comment Print


Latest Notifications


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 246 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 9252 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 4098 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 5511 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 3021 Views 0 comment Print


Limitation date for reopening cases related to Ashish Agarwal judgment

February 6, 2023 5511 Views 0 comment Print

Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cases, in the light of communication sent by ITBA. The Board is of the view that such cases have to be completed by 31.05.2023

Exclusion of 15 day period for issuance of section 148 notice in Search cases

February 5, 2023 5544 Views 0 comment Print

In cases where a search under section 132 is initiated or a search for which the last of the authorization is executed or requisition is made under section 132A, after the 15th March of any financial year a period of fifteen days shall be excluded for the purpose of computing the period of limitation for issuance of notice under section 148 and the notice so issued shall be deemed to have been issued on the 31st day of March of such financial year.

Information triggering assessment/ reassessment proceedings must be furnished to assessee

February 4, 2023 1656 Views 0 comment Print

HC set aside reassessment order against assessee, for non-supply of information/ material by Revenue Department for reopening of assessment.

Draft submission when AO not complies with section 147 to 151 of Income Tax

February 2, 2023 5025 Views 0 comment Print

Draft submission to ITAT when AO doesn’t comply with section 147 to 151 of Income Tax. Ground of Appeal & Arguments in writing, AO’s reasons recorded u/s 148(2) were never supplied to assessee. Assessment bad in law & spirits as reopening bad enough.

Time barring date for reopening cases arising out of SC direction

February 2, 2023 3021 Views 0 comment Print

Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, West Bengal & Sikkim Region, Kolkata. Sir, Sub: Time barring date for reopening cases arising out of the direction of the Hon’ble SC in the case of Ashish Agarwal-matter regarding. Your kind attention is invited to the minutes […]

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

January 27, 2023 14991 Views 1 comment Print

CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruction No. 01/2022 dated 11.05.2022 shall be completed on or before 31.05.2023.

Reopening of assessment sustained due to failure of true & full disclosure

January 23, 2023 798 Views 0 comment Print

Gujarat High Court held that reopening of assessment sustainable on failure of true and full disclosure of demanded material on the part of the petitioner.

Re-opening of assessment in absence of any new tangible material is unsustainable

January 23, 2023 1353 Views 0 comment Print

Bombay High Court held that in absence of any receipt of new information or reference to any new material on record, it can be concluded that re-opening of assessment is merely because of change of opinion and the same is unsustainable in law.

Reassessment only on account of ‘change of opinion’ is liable to be struck down

January 19, 2023 1164 Views 0 comment Print

Rajasthan High Court held that reassessment resorted only on account of ‘Change of opinion’ of AO and without there being any fresh tangible evidence for reopening the assessment proceedings is liable to be struck down.

Re-opening of assessment unjustified as complete disclosure of primary material facts already submitted

January 19, 2023 795 Views 0 comment Print

Bombay High Court held that re-opening of assessment under section 147 of the Income Tax Act is unjustified as the assessee provided complete disclosure of all the primary material facts during the scrutiny assessment.

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