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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 90 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


ITAT Delhi quashes reassessment Due to Unsigned Section 151 Approval

November 25, 2025 1047 Views 0 comment Print

The Tribunal held that reassessment proceedings initiated without a properly signed Section 151 approval are invalid. The notice under Section 148 was quashed, and the assessee’s appeal was allowed.

ITAT Delhi deletes Protective Additions Due to Absence of Substantive Assessment

November 25, 2025 519 Views 0 comment Print

Tribunal deleted protective additions after finding no corresponding substantive assessment. The ruling clarifies that protective action cannot stand alone under Sections 147/143(3).

Section 54F Deduction Denied Due to Lack of Proof of Property Ownership

November 25, 2025 423 Views 0 comment Print

Tribunal upheld disallowance of Section 54F exemption after the assessee failed to prove ownership of the residential property. The ruling confirms that deduction requires clear evidence of title.

Tribunal Dismisses Revenue Appeal Over Time-Barred Reassessment

November 25, 2025 318 Views 0 comment Print

The Tribunal ruled that once the assessee responds to a 148A(b) notice, the AO must complete the 148A(d)–148 cycle within the remaining time. In this case, the notice overshot the surviving limitation period, making reassessment legally defective. Consequently, all additions related to alleged accommodation entries and loans were quashed.

AO’s Reopening Under Section 147 Set Aside Over Incorrect Filing Claim

November 25, 2025 516 Views 0 comment Print

Tribunal quashed reopening under Section 147 where AO’s presumption of non-filing contradicted the documented return, citing Deepak Wadhwa precedent.

Revenue Appeal Dismissed: 143(2) Notice Mandatory for 148 Cases

November 25, 2025 813 Views 0 comment Print

The Tribunal held that reassessment under Sections 147/143(3) is invalid without a Section 143(2) notice. It ruled that using the return filed under Section 148 triggers the mandatory requirement.

Bogus Purchase Addition Unsustainable When Purchases Confirmed by GST Order

November 25, 2025 2064 Views 0 comment Print

Assessee succeeded in cross-objection as reassessment lacked jurisdiction and Section 69C addition was inapplicable, confirming deletion of addition and quashing proceedings.

No Independent Verification – Accommodation Entry Addition Unsustainable: ITAT Chandigarh

November 25, 2025 531 Views 0 comment Print

Tribunal held that addition for alleged accommodation entry could not stand where AO made no independent verification. Genuine sales, banking-channel receipts and tax records supported deletion.

ITAT Bangalore Quashed Reassessment Over Missing Section 143(2) Notice

November 25, 2025 483 Views 0 comment Print

ITAT Bangalore set aside reassessment orders for AY 2015-16 to 2017-18, ruling that failure to issue mandatory notice under section 143(2) of the Income Tax Act invalidates the proceedings.

₹29.69 crore Bogus Purchases Addition Quashed as Notice Issued by JAO instead of FAO

November 25, 2025 960 Views 0 comment Print

ITAT quashed reassessment notice issued by Jurisdictional AO instead of Faceless AO. Addition of ₹29.69 crore was invalidated, and Revenue’s appeal became infructuous.

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