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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


Bogus Purchases from Five Hawala Suppliers: ITAT Delhi Restricts Profit Estimation to 8%

November 27, 2025 465 Views 0 comment Print

The Court reviewed bogus purchases of Rs. 4.65 crore, confirming the purchases as unverifiable but reduced the income estimation from 12.5% to 8%. The appeal was partly allowed, providing relief to the assessee.

Double Taxation Not Permitted: ITAT Mumbai Deletes 2% Estimated Profit Added in Hands of Partnership Firm

November 27, 2025 378 Views 0 comment Print

The ITAT Mumbai ruled that income already taxed under a proprietorship cannot be taxed again in a partnership, deleting the estimated 2% addition by CIT(A).

Objections Not Disposed = Reopening Void: ITAT Delhi Affirms CIT(A), Quashes 147 Assessment

November 27, 2025 462 Views 0 comment Print

ITAT Delhi upheld that failure to pass a speaking order on objections under GKN Driveshafts makes reassessment void, dismissing Revenue’s appeal for AY 2012-13

Notice by Jurisdictional AO, Assessment by NFAC Held Invalid: ITAT Quashes Entire 147 Proceedings

November 27, 2025 684 Views 0 comment Print

The Tribunal held the reassessment invalid as NFAC completed the process without issuing a mandatory notice under section 148A. It ruled that an assessment is void when the jurisdictional notice is issued by one authority but finalized by another.

ITAT Mumbai Quashes Reassessment as Notice Issued by Non-Jurisdictional AO

November 27, 2025 612 Views 0 comment Print

The ITAT ruled that a reassessment notice issued by a non-jurisdictional officer is void, quashing a demand of ₹1.01 crore and invalidating the assessment.

Change of Opinion Cannot Justify Reopening: ITAT Quashes 147

November 27, 2025 501 Views 0 comment Print

The ITAT Mumbai invalidated the reopening of an income-tax assessment under section 148, holding that no new tangible material was found. Interest income from co-operative banks and other receipts had already been considered in the original assessment. 

Uncrossed Third-Party Statement Not Enough to Establish Bogus Purchases

November 27, 2025 678 Views 0 comment Print

Tribunal dismisses AO’s addition after assessing evidence, books of accounts, VAT returns, and confirmed ledgers, confirming the transactions’ authenticity.

ITAT Mumbai: Corrigendum Cannot Cure Defective Section 148 Notice

November 27, 2025 474 Views 0 comment Print

ITAT Mumbai invalidated the reassessment for AY 2008-09 because the notice under section 148 was issued after the statutory limitation period and contained a clerical error in the assessment year. The ruling underscores the necessity of strict procedural compliance for reassessment.

Reassessment Beyond 3 Years Quashed Due to Wrong Sanctioning Authority

November 27, 2025 582 Views 0 comment Print

The Tribunal held that a reopening made after three years is void when approval is granted by the PCIT instead of the PCCIT/CCIT. The entire reassessment and related disallowance were struck down.

ITAT Directs Recalculation of Capital Gains, Not Just Section 50C Difference

November 27, 2025 444 Views 0 comment Print

The Tribunal held that AO must recompute capital gains considering purchase cost, indexation, and stamp duty, instead of merely adding the section 50C deemed value difference.

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