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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


JAO-Issued Reassessment Notices Quashed for Violating Faceless Scheme

November 28, 2025 1188 Views 0 comment Print

The Telangana High Court ruled that Section 148 notices for central charge cases must follow the faceless procedure under the Finance Act, 2021, quashing JAO-issued notices.

Exemption Under Section 54F Allowed for Multiple Flats by Madras HC

November 28, 2025 1137 Views 0 comment Print

The Madras High Court ruled that Section 54F of the Income Tax Act can cover multiple residential units purchased from capital gains, reversing the ITAT’s single-flat restriction.

No Firm, No Assessment: ITAT Mumbai Strikes Down 147 on Dissolved Partnership

November 28, 2025 378 Views 0 comment Print

The Tribunal concluded that section 189 is only a machinery provision and cannot be invoked to assess alleged income arising long after a firm has ceased to exist. Since no evidence showed any business activity post-2012, the reopening for AY 2017-18 was invalid. The order quashing the reassessment also nullified the related addition and penalty.

No Section 270A Penalty When Cess Claim Made in Good Faith and Withdrawn Post-Amendment

November 28, 2025 990 Views 0 comment Print

The Tribunal ruled that a cess deduction claim based on favourable jurisprudence cannot trigger penalty. Compliance with Section 155(18), including timely Form 69 filing, protected the assessee from under-reporting allegations.

Assessment Reopening Quashed Due to Defective Reasons and Roving Inquiry

November 28, 2025 1023 Views 0 comment Print

ITAT held that reassessment notices under sections 147/148 were invalid as the reasons were vague and lacked tangible evidence. Reopening cannot be used merely to verify or scrutinize transactions without proper justification.

Time-Barred Notices Under Section 148 Lead to Quashing of Assessments

November 28, 2025 2343 Views 0 comment Print

The Court held that reassessment notices under Section 148 issued beyond the surviving period under TOLA are invalid, leading to quashing of assessment orders. Time-bar limits override procedural provisions.

AO’s Purchase + Sale Formula Rejected: Reassessment Sent Back for Proper Inquiry

November 28, 2025 474 Views 0 comment Print

Demat and broker records showed actual purchases of Rs. 1.24 crore and sales of Rs. 85 lakh, contradicting the AO’s addition of Rs. 2.11 crore. The Tribunal remitted the matter for detailed examination. Proper transaction-wise verification is essential before treating share activity as unexplained income.

ITAT Rules 148 Notice Void Due to Wrong Authority’s Approval in Reopening After 4 Years

November 28, 2025 525 Views 0 comment Print

The Tribunal held that reassessment after four years requires PCIT approval, not Additional CIT. The invalid sanction led to quashing of the Section 148 notice and dismissal of Revenue’s appeal.

Jurisdictional Misfire -Wrong Sanction Sinks Reopening: PCIT Approval Not Enough Beyond 3 Years

November 28, 2025 486 Views 0 comment Print

The ITAT held that reassessment notices issued without the correct statutory sanction under section 151(ii) are void ab initio, emphasizing that procedural compliance is crucial before examining merits of the case.

No LTCG Claim, No Penny-Stock Benefit: ITAT Mumbai Deletes Addition & Allows Appeal

November 27, 2025 459 Views 0 comment Print

Reopening Based on Incorrect LTCG Information Invalid; Long-Held Penny-Stock Shares Treated as Genuine — ITAT Mumbai Quashes Additions

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