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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 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


AY 2015-16 Reassessment Time-Barred if notices issued Post-1 Apr 2021: Bombay HC

November 25, 2025 1056 Views 0 comment Print

The Bombay High Court held that a reassessment notice issued under Section 148 on 5th April 2022 is barred by limitation, following the Supreme Court’s Rajeev Bansal decision and prior High Court rulings.

ITAT Remands Case as Notices Sent to Wrong Email; Assessee Directed to Pay ₹5,000 Costs

November 25, 2025 432 Views 0 comment Print

The Tribunal found that hearing notices were sent to the wrong email address, resulting in an ex-parte order. The matter was remanded to the AO after directing the assessee to deposit ₹5,000 as costs.

Penalty Deleted: Credits Were Already Declared as Interest Income

November 24, 2025 291 Views 0 comment Print

ITAT Delhi admitted additional evidence proving that bank credits considered unexplained were interest income already declared in returns. The Revenue could not contest the factual reconciliation. The penalty under section 271(1)(c) was deleted in full.

Reopening of assessment cannot be based on change of opinion

November 24, 2025 750 Views 0 comment Print

Bombay High Court held that reopening of assessment proceedings on the basis of change of mind/opinion and also on non-application of mind is liable to be quashed and set aside. Accordingly, impugned notices and order quashed.

Bogus Purchase Addition Remanded as CIT(A) Ignored Books and Evidence

November 24, 2025 219 Views 0 comment Print

The Tribunal held that the CIT(A) erred by relying solely on an investigation report without examining books and invoices, and therefore sent the matter back for fresh consideration.

Deduction u/s 80-O was allowable on Overseas Advisory Services rendered from India

November 24, 2025 495 Views 0 comment Print

Professional and technical advisory services rendered from India to foreign clients in connection with overseas securities offerings qualify for deduction under Section 80-O as there was coordinate Bench’s decision in the assessee’s own case for AY 1995-96

Mere NMS-triggered email alert without basis cannot justify reassessment: ITAT Delhi

November 23, 2025 1305 Views 0 comment Print

The Tribunal held that reopening based solely on an NMS alert and without examining DTAA-exempt interest income violated Section 115A(5). The ruling confirms that non-residents cannot be reassessed when TDS-deducted income does not escape tax.

AIR Additions Without Disclosure Invalid; Assessment Remanded for Fresh Hearing

November 23, 2025 330 Views 0 comment Print

ITAT Mumbai quashed ex-parte assessment based solely on AIR entries, directing AO to provide full details so assessee can respond and defend his position.

Reassessment Orders Quashed for Notices Issued to Deceased Assessee

November 23, 2025 2418 Views 0 comment Print

The Tribunal held that notices and assessment orders in the name of a deceased person have no legal standing, confirming that reassessment requires a living assessee or representative.

Reopening Quashed—AO Recorded Wrong Facts, Wrong Amounts & Even Wrong Name;

November 22, 2025 435 Views 0 comment Print

ITAT found that reopening relied on wrong bank deposits, incorrect assessee details, and a mechanical sanction under section 151. The reassessment under sections 144/147 and the ₹15 lakh unexplained cash addition were deleted.

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