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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 90 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 5745 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


ITAT Delhi Quashes Reopening for Wrong AY, No Failure to Disclose & Mechanical Approval

November 18, 2025 267 Views 0 comment Print

The ITAT Delhi invalidated the reopening of an income tax assessment because the assessee had filed a complete return and the AO failed to record valid reasons, highlighting the need for proper statutory compliance in reassessment.

ITAT Restores ₹15 Crore Cash Addition: CIT(A) Failed to Seek Remand Report & Violated Rule 46A

November 18, 2025 342 Views 0 comment Print

The ITAT Raipur restored the appeal regarding deletion of ₹15.81 crore addition, highlighting procedural lapses by CIT(A) in accepting new evidence without remand. Key takeaway: AO’s verification is crucial before deleting large additions.

Revision u/s 263 Quashed: No Specific Error Identified by PCIT

November 18, 2025 432 Views 0 comment Print

ITAT held that section 263 cannot be invoked unless the PCIT pinpoints an actual error in the AO’s order; since no specific mistake was shown, the revision was invalid.

Contractual Late Delivery Charges Not Penalty, Reopening Without New Material invalid

November 18, 2025 537 Views 0 comment Print

The Tribunal held that reassessment was invalid since the original scrutiny had already examined the issue and no fresh information indicating suppression or omission was found. Reopening based solely on a change of opinion was rejected. The ruling reinforces that section 147 requires tangible new material.

Section 69A Addition Deleted: AO Must Prove Cash Deposit Isn’t Sale Consideration

November 18, 2025 630 Views 0 comment Print

The Tribunal ruled that authorities erred by ignoring the sale deed, receipt, and bank statements solely due to a technical lapse in return filing. Since the documents clearly established the source of cash, the addition could not survive. The order directed deletion of the section 69A addition.

Reassessment proceedings initiated with approval from wrong authority is invalid: ITAT Delhi

November 18, 2025 720 Views 0 comment Print

Reassessment proceedings initiated with approval from the wrong authority were held invalid. Courts reiterated that Section 151(ii) specifies the competent sanctioning authority for notices issued after three years, leading to quashing of the assessment and related demand.

ITAT Delhi Quashes Section 147 and 148 Proceedings Over Improper Section 151 Sanction

November 17, 2025 447 Views 0 comment Print

ITAT Delhi held that the PCIT’s sanction under section 151 was granted before the AO recorded reasons to reopen the assessment, violating mandatory procedural requirements. As the jurisdictional defect went to the root, the section 148 notice and entire section 147 reassessment were declared void ab initio.

ITAT Ahmedabad Rejects 263 Revision Over Proper AO Verification

November 17, 2025 432 Views 0 comment Print

ITAT Ahmedabad held that the AO had conducted detailed enquiries into long-term capital gains from penny stock transactions, and the PCIT’s revision under section 263 was based only on an audit objection. Since the AO’s view was plausible and well-supported, the revisional action was unsustainable and quashed.

No Evidence, No Rigging, No Bogus LTCG – Penny-Stock Theory Fails

November 17, 2025 5334 Views 0 comment Print

The order reiterates that mere unusual price movement or high returns do not convert a scrip into a penny stock. With identical facts earlier examined and accepted, the Tribunal followed precedent and removed all additions.

Section 151A Breach: ITAT Quashes Reopening, ₹58.68 Cr Bogus Purchase Addition Deleted

November 16, 2025 1506 Views 0 comment Print

 ITAT Chandigarh held that a Section 148 notice issued by the Jurisdictional AO instead of Faceless AO violated statutory provisions, quashing the assessment for AY 2016-17.

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