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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 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 57 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 255 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 735 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


Kerala HC allows Alka Ventures Appeal on Condition of ₹12 Crore Advance Tax deposit

April 9, 2024 234 Views 0 comment Print

Kerala High Court orders Alka Ventures Pvt Ltd to pay 12 crore as advance tax for appeal against assessment order. Details of the judgment provided.

ITAT slams AO & CIT(A) for Unwarranted litigation, incompetence & casual approach 

April 5, 2024 1581 Views 1 comment Print

ITAT Mumbai deletes addition on whole amount from sale of shares in Nikunj Kaushik Shah Vs ITO case, criticizing unwarranted litigation, incompetence & casual approach 

Section 68 addition invalid if creditworthiness proven: ITAT Delhi

April 4, 2024 786 Views 0 comment Print

In the ITAT Delhi case I.T.O Vs Placid Buildwell Pvt Ltd, the addition u/s 68 was deemed invalid as creditworthiness was proven. Detailed analysis here.

PCIT Cannot invoke Section 263 jurisdiction Solely Based on Disagreement with AO’s Plausible View

April 4, 2024 279 Views 0 comment Print

Analysis of Satbir Mahato Vs PCIT case by Kolkata ITAT, highlighting the dispute over Section 263 jurisdiction due to plausible views of AO.

Share capital/premium cannot be added to income for mere non-compliance of summons by subscribers

April 4, 2024 474 Views 0 comment Print

In the Nano Infra Promoters Pvt Ltd vs ITO case at ITAT Kolkata, learn why receipts couldn’t be added to income under section 68 just for summons non-compliance.

Shyam Sunder Khandelwal Vs ACIT: Interplay between Sections 147/148 & 153C

April 3, 2024 4308 Views 0 comment Print

Dive into the detailed analysis of the Shyam Sunder Khandelwal Vs ACIT case by Rajasthan High Court, exploring the applicability of Sections 153C and 148 of the Income Tax Act. Understand the implications and conclusions drawn.

No reassessment for Client code modification on failure to prove malafide purpose of shifting profit  

April 3, 2024 309 Views 0 comment Print

Reassessment proceedings on the ground that assessee was one of the beneficiary of Client Code Modification (CCM) by some broker was quashed as there was no material to infer that such client code modification had been done with the malafide purpose of shifting  the profit or evasion of the tax.

No TDS on Sales Commission to Wholly-Owned Subsidiary under Section 40(a)(i)

April 3, 2024 348 Views 0 comment Print

TDS was not to be deducted on payments to Manthan Systems Inc. (MSI) for sales commission under section 40(a)(i) as services rendered to assessee by the said Manthan Systems Inc. was not falling within the ambit of FTS or under Article 12 of the treaty, assessee was not liable to deduct TDS on the payment made to the MSI.

Failure to Record Satisfaction Renders Section 148 Notice Void & Assessment Order Void-ab-initio

April 3, 2024 657 Views 0 comment Print

Analysis of ITAT Mumbai’s ruling on void-ab-initio notice under Section 148 & assessment order. Non-recording of satisfaction renders proceedings unsustainable.

Section 148 Notice cannot be issued to Partner for Transactions Among Partnership Firms

April 3, 2024 639 Views 0 comment Print

Explore the case of Bhagwan Laxman Rokde Vs ITO (ITAT Mumbai) regarding validity of reopening u/s.147, taxation on undisclosed income, and partnership firm transactions.

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