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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 4950 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1653 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 909 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2490 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...

March 9, 2025 9 Views 0 comment Print

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....

March 9, 2025 21 Views 0 comment Print

ITAT Surat Directs Re-examination of Tax on Gift from HUF

Income Tax : ITAT Surat remands case to CIT(A) for fresh adjudication on HUF gift taxability under Section 56(2)(vii) of the Income Tax Act, ci...

March 9, 2025 45 Views 0 comment Print

Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 207 Views 0 comment Print

Retrospective Amendment Doesn’t Justify Reassessment Beyond Four Years

Income Tax : Bombay High Court sets aside IT reassessment against Oxford University Press, ruling no failure to disclose material facts for reo...

March 8, 2025 138 Views 0 comment Print


Latest Notifications


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 246 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 9252 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 4083 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 5511 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 3021 Views 0 comment Print


Assessment Issued in Wrong Name Post-Merger Not Correctable Under Section 292B

January 22, 2025 474 Views 0 comment Print

Despite there was a valid disclosure made by assessee and AO being duly apprised of the factum of merger, AO made the draft assessment order in the name of a party which no longer existed on that date.

Is entity having ‘Permanent Establishment’ was a fact-specific issue to be determined separately for different tax periods

January 22, 2025 270 Views 0 comment Print

Whether or not a permanent establishment existed in a State during a given period must be determined on the basis of the circumstances applicable during that period and not those applicable during a past or future period.

ITAT Restores ₹10 Lakh Section 35AC Donation Disallowance to AO

January 21, 2025 528 Views 0 comment Print

ITAT Ahmedabad remands ₹10 lakh donation disallowance under Section 35AC to AO for reassessment. Assessee’s appeal partially allowed for statistical purposes.

ITAT Remands Case to AO, Allows Assessee to Explain Investments

January 21, 2025 303 Views 0 comment Print

ITAT Ahmedabad order in Maheshbhai Nagjibhai Desai Vs ITO case, addressing reopening under Section 147 and unexplained investments under Section 69.

ITAT Ahmedabad Remands Case on Unexplained Investments to AO

January 21, 2025 243 Views 0 comment Print

ITAT Ahmedabad remands case on unexplained investments of ₹18.19L in land & shares. Tribunal directs re-examination by AO after Assessee presents evidence.

No power to Designated Authority to reopen concluded cases under Vivad se Vishwas Act

January 20, 2025 912 Views 0 comment Print

There was no provision under the DTVSV Act that empowered a Designated Authority to reopen a concluded settlement. Once a final certificate was issued under Section 5(1), all disputes with regard to the ‘tax arrear’ stood concluded.

Addition on grounds not forming part of reasons recorded for reopening of assessment not tenable

January 20, 2025 120 Views 0 comment Print

ITAT Ahmedabad held that addition on grounds other than grounds forming part of reasons recorded for reopening of assessment not justified. Accordingly, addition towards unexplained investment which didn’t form part of reasons liable to be deleted.

Ground not addressed by CIT(A) cannot be taken up by ITAT: Delhi HC

January 20, 2025 372 Views 0 comment Print

Delhi High Court held that ITAT cannot address the ground which remained unaddressed by CIT(A). Accordingly, matter restored back to CIT(A) to decide on the grounds that were not decided.

Provision for leave salary not allowable as deduction u/s. 43B(f): Madras HC

January 18, 2025 1380 Views 0 comment Print

Madras High Court held that provision for leave salary is not allowable as deduction under section 43B(f) of the Income Tax Act since deduction of actual payment is allowable and not of provision. Accordingly, question of law answered in favour of revenue.

Both the parties agreed to treat the addition as business receipts: ITAT directed AO to assess profit @ 8%

January 18, 2025 1134 Views 0 comment Print

Assessee didnot file return for the year under consideration. As per AIMS module information received that assessee has deposited the amount of Rs.16,84,100/- as cash during the demonetization period. Case was reopened notice was issued accordingly.

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