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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 6009 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 1671 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 924 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 2502 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


Addition u/s. 68 restricted to 0.30% of total Circular Trading Transaction: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that CIT(A) rightly restricted disallowance on account of unexplained bank deposit and withdrawal under sectio...

March 10, 2025 63 Views 0 comment Print

Reassessment not Change of Opinion if original assessment not involve any formation of opinion

Income Tax : It was held that in the original assessment under Section 143(1), the issue related to the deed of purchase of land was not looked...

March 10, 2025 42 Views 0 comment Print

Reassessment notice issued u/s. 148 beyond six years is time barred: ITAT Mumbai

Income Tax : ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. A...

March 10, 2025 663 Views 0 comment Print

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 156 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 264 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 4101 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


Time Travel in Avengers Endgame Visualised in Income Tax Act

May 19, 2022 4080 Views 0 comment Print

Explore the mind-bending time travel concept of Avengers Endgame visualized through the lens of the Income Tax Act.

Bankers Blunders resulting in flood of Section 148/148A notices

May 17, 2022 18501 Views 2 comments Print

Bankers Blunders resulting in flood of IT Notices U/s 148A, U/s 148 etc., leaving Bruises  to IT Assessees for no fault of them –Real Cases analysed

Change of opinion not constitutes reason to believe for Income escapement

May 17, 2022 1533 Views 0 comment Print

Change of opinion does not constitute justification and/or reason to believe that income chargeable to tax has escaped assessment.

Reopening not allowable to disallow prior period expenses duly disclosed during original Assessment

May 15, 2022 840 Views 0 comment Print

ITAT Delhi held that Reopening not allowable to disallow prior period expenses which were duly disclosed during original Assessment in Financial Statements and Tax Audit report

Reopening by change of opinion on facts already examined is not valid

May 15, 2022 1176 Views 0 comment Print

Re-opening proposed is purely based on change of opinion and entire issue which is subject matter of reasons recorded has been raised during assessment proceedings

Allowing mere 8 hours to reply to SCN is neither reasonable nor effective

May 15, 2022 2016 Views 0 comment Print

Court is of the view that time of eight hours to file reply to the show cause notice was neither reasonable nor effective, as within this short time, the Petitioner could not have supplied relevant information and documents to substantiate his case.

An Appeal to Regularize Income Tax Reassessment Proceedings

May 14, 2022 5751 Views 0 comment Print

Unlock the intricacies of Income Tax reassessment proceedings under Section 147 of the Income Tax Act, 1961. Explore key amendments through the Finance Act, 2021, including the introduction of Section 148A. Delve into the implications of notices, time limits, and the recent legal developments. Stay informed on the changing landscape of tax reassessment.

Reassessment Based on wrong and incorrect facts is bad in law

May 14, 2022 3360 Views 0 comment Print

Keshav Saran Vs ACIT (ITAT Delhi) In the present case, the assessee has actually filed the return of income and the Assessing Officer in the satisfaction note noted that the assessee has not filed return of income. Thus, we safely presume that the Assessing Officer has initiated reassessment proceedings by mentioning wrong and incorrect facts […]

Reopening on wrong assumption of facts by AO cannot be sustained

May 14, 2022 1038 Views 0 comment Print

ITAT held that that the A.O. has ventured on a wrong assumption of facts though the agreement was available on hand with the A.O. in the original assessment proceedings. Considering the facts and circumstances are of the opinion that the reopening on the wrong assumption of facts by the assessing officer cannot be sustained.

HC quashes Reassessment order passed Without issuing Section 148 Notice

May 14, 2022 498 Views 0 comment Print

Govardhan Commodities Pvt. Ltd. Vs. ACIT/DCIT (Calcutta High Court) In this matter, petitioner has challenged the impugned assessment order dated 19th March, 2022 under Section 147 read with Section 144 of the Income Tax Act, 1961 relating to the assessment year 2014-15 being Annexure P-5 to the writ petition, on the ground that the same […]

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