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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 81 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 108 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 90 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


Commission Rationalised to 0.40% on Sales/Purchases & 0.50% on Loans by ITAT Mumbai

November 22, 2025 483 Views 0 comment Print

The Tribunal reduced commission estimations for sale/purchase and loan entries to 0.40% and 0.50%, excluding intra-group transactions. This ensures compliance with judicial precedents and prevents arbitrary income additions.

Capital Gains Recomputed Using ₹50,000/Bigha for Co-Owner Consistency

November 22, 2025 255 Views 0 comment Print

Tribunal directed AO to maintain uniformity among co-owners in computing capital gains. While circle rate under section 50C applies, the cost of acquisition should follow the previously accepted benchmark of ₹50,000 per bigha.

Penny Stock Allegations Rejected: ₹1.25 Cr & ₹1.53 Lakh Additions Deleted

November 22, 2025 423 Views 0 comment Print

ITAT Ahmedabad held that speculative intraday trades are genuine and not accommodation entries. Additions under Section 68 totaling ₹1.25 crore and ₹1.53 lakh were deleted due to lack of foundational facts and proper inquiry.

Low Income of Investors Cannot Trigger Section 68 Addition: ₹3.32 Cr Deleted

November 22, 2025 450 Views 0 comment Print

ITAT Kolkata deleted ₹3.32 crore addition under Section 68, holding that complete documentary evidence proved the genuineness and identity of investors. Low income or meagre business activity of subscriber companies cannot justify treating share capital as unexplained.

Automated Allocation Mandatory for Income Tax Reassessment Notices: Jharkhand HC

November 22, 2025 909 Views 0 comment Print

The court reaffirmed that reassessment notices under Section 148 must be issued via the CBDT-prescribed automated system. Notices issued by local officers without allocation are considered without jurisdiction.

Section 148 Notice by JAO Quashed, Faceless Assessment Applies from Notice Stage

November 22, 2025 5829 Views 0 comment Print

Punjab and Haryana High Court held that a Section 148 notice issued by a Jurisdictional Assessing Officer after the faceless assessment scheme is invalid. The notice contravened Section 151A and the 2022 e-Assessment scheme. The court quashed the notice with directions to follow statutory faceless procedure.

CIT(A) Wrongly Refused Additional Evidence on Technical Ground: Matter Remanded for Fresh Decision

November 21, 2025 306 Views 0 comment Print

Tribunal emphasized reasonable opportunity of hearing and proper consideration of all evidence to resolve disputed reassessment under Section 147/144.

Reassessment Quashed u/s 151 for Wrong Authority Beyond 3 Years

November 21, 2025 465 Views 0 comment Print

ITAT Delhi held that obtaining sanction u/s 151 from PCIT instead of PCCIT for reopening beyond 3 years invalidates reassessment. Jurisdictional defect renders entire proceedings void.

ITAT Mumbai Upheld MAT Liability Despite Prior SICA Status Due to Positive Net Worth

November 21, 2025 348 Views 0 comment Print

The Tribunal held that MAT relief under section 115JB cannot continue once a company’s net worth becomes positive, as the scheme required only consideration—not automatic grant—of exemption.

Cash Deposit Linked to Property Sale: ITAT Sends Matter Back for Fresh Examination

November 21, 2025 621 Views 0 comment Print

The Tribunal set aside the ex parte confirmation of a cash-deposit addition and directed fresh examination after the assessee produced sale-related documents. The key takeaway is that additions under section 69 require proper verification of evidence.

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