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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


Karnataka HC Quashes Reassessment Notices Issued Beyond Section 151A Scope

November 22, 2025 723 Views 0 comment Print

Karnataka High Court quashed several notices, assessment orders, and bank garnishments issued under sections 148A, 147, 156, and 226(3), allowing the cooperative federation’s petition.

75-Day Delay Condoned as Assessee Relied on Negligent Consultant; 144 Order Restored

November 22, 2025 501 Views 0 comment Print

ITAT Mumbai condoned 75-day delay in filing appeal, recognizing assessee’s illiteracy and reliance on tax consultant, allowing fresh adjudication on merits.

Entire ₹11 Lakh Cash Deposit Addition Deleted on Full Explanation

November 22, 2025 369 Views 0 comment Print

AO treated ₹13 lakh cash deposits as unexplained, but ITAT found all deposits supported by cash book and bank self-cheques. Entire addition under section 68 was deleted.

Reassessment Declared Void as AO Skipped Mandatory Section 143(2) Notice

November 22, 2025 1125 Views 0 comment Print

ITAT held reassessment invalid where AO acted on belated return without issuing mandatory 143(2) notice. Entire reassessment under sections 144/147 was quashed despite late filing of return.

LTCG not Triggered Without Registered JDA & Statutory Approvals: ITAT Visakhapatnam

November 22, 2025 2223 Views 0 comment Print

The ITAT upheld the CIT(A)’s deletion of Rs. 11.26 crore LTCG, noting the unregistered JDA could not constitute a transfer under Section 2(47)(v). Taxability arises only upon registration and statutory approvals.

ITAT Remands CIT(A) Order for Non-Speaking Decision on 54/54F & Net Consideration

November 22, 2025 894 Views 0 comment Print

Tribunal found the appellate order non-speaking, failing to consider multiple submissions including 54F claims and compensation deductions. The matter is remanded for comprehensive review and proper opportunity of hearing.

ITAT Restores Appeal After NFAC Rejected Rectification Due to Portal Visibility Error

November 22, 2025 546 Views 0 comment Print

CIT(A) wrongly rejected the assessee’s rectification petition under section 154 despite portal evidence. ITAT restored the appeal for fresh adjudication with full opportunity to submit evidence.

Loans Repaid – Section 68 Cannot Apply: ITAT Kolkata

November 22, 2025 924 Views 0 comment Print

With all Section 68 additions deleted across the three years, the basis for penalties under Section 271(1)(c) disappeared. The Tribunal directed complete removal of penalties, highlighting that concealment cannot be presumed when additions themselves lack merit. The ruling reinforces the principle that penalty proceedings cannot survive defective assessments.

ITAT Orders AO to Examine Additional Section 54B Claim Omitted in Return

November 22, 2025 309 Views 0 comment Print

ITAT rules that an additional 54B claim omitted in the original return cannot be mechanically rejected. AO must examine the claim on merits, verifying capital gains utilisation and statutory conditions.

Reopening Quashed – Reasons Based on Wrong Facts Mechanical 151 Approval; Rule-27 Legal Ground Allowed

November 22, 2025 537 Views 0 comment Print

Tribunal invalidates reassessment where AO relied on incorrect data and PCIT granted mere Yes approval. Highlights importance of independent application of mind under Sections 147/148/151.

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