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Section 147

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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 2841 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 69 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 105 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 96 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 90 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 447 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 5742 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


Appeal Cannot Be Dismissed for Non-Payment of Advance Tax When No Taxable Income Exists

April 13, 2026 324 Views 0 comment Print

ITAT held that section 249(4) cannot be invoked where no taxable income arises in India. Appeals must be decided on merits rather than dismissed on technical grounds.

ITAT Mumbai: Second Reopening Based on Same Material Is Invalid-Change of Opinion Not Permissible

April 13, 2026 192 Views 0 comment Print

The Tribunal ruled that reassessment cannot be reopened on issues already examined earlier. It held that absence of fresh material and mere change of opinion renders reopening invalid.

ITAT Mumbai: Reopening Invalid Without Proper Sanction-Approval by Wrong Authority Vitiates Entire Proceedings

April 13, 2026 252 Views 0 comment Print

ITAT Mumbai holds reassessment invalid where approval under Section 151 was obtained from incorrect authority, ruling defect as jurisdictional and quashing notice under Section 148 and consequent proceedings.

ITAT Mumbai: Reopening Beyond 3 Years Invalid Where Escaped Income below ₹50L-Notice u/s 148 Quashed

April 13, 2026 180 Views 0 comment Print

ITAT Mumbai quashes reopening beyond 3 years where escaped income is below ₹50 lakh, holding notice under Section 148 time-barred and invalid, thereby deleting consequential addition.

ITAT Mumbai: Reopening Invalid Without Proper Sanction-Entire Assessment Quashed

April 13, 2026 516 Views 0 comment Print

ITAT Mumbai quashed reassessment as approval under Section 151 was obtained from the wrong authority. Notice under Section 148 held invalid, making entire proceedings void ab initio.

Reassessment Quashed as Time-Barred Due to Post-2021 Notice for AY 2015–16

April 11, 2026 582 Views 0 comment Print

The Tribunal invalidated reassessment proceedings since the Section 148 notice was issued after 01.04.2021, making it time-barred. The ruling reinforces strict limitation compliance for reopening cases.

No Section 68 Addition on Sales Already Offered to Tax: ITAT Mumbai

April 10, 2026 381 Views 0 comment Print

The Tribunal held that recorded sales forming part of turnover cannot be treated as unexplained cash credits. The key takeaway is that taxing gross sales again is impermissible in law.

Reopening Invalid as Based on Issue Already Decided in Earlier Year: Gujarat HC

April 10, 2026 276 Views 0 comment Print

The case examined reopening based on a prior disallowance under Section 80IB(10). The Court found that the disallowance had already been reversed by appellate authorities. Therefore, reopening based on the same ground was held invalid.

Non-service of statutory notice prior to initiation of proceedings u/s. 148 not tenable: Matter remitted

April 10, 2026 141 Views 0 comment Print

Orissa High Court held that assessment order set aside as proceedings under section 148 of the Income Tax Act initiated without serving of statutory notice. Accordingly, matter remitted back to AO to serve notice u/s. 148 as not hit by limitation u/s. 149.

Unexplained Cash Deposits Addition Reduced Because Only Peak Balance Taxable: ITAT Ahmedabad

April 10, 2026 414 Views 0 comment Print

ITAT confirmed validity of reassessment based on cash deposit information. However, it reduced addition by applying peak credit theory due to withdrawal patterns

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