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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 5814 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 1665 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 921 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 2499 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


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 420 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 126 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 156 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 231 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 255 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


Reassessment after 4 years not valid If Assessee Made Full & True Disclosure during original assessment

April 13, 2022 1056 Views 0 comment Print

Ranjana Aggarwal Vs ITO (ITAT Delhi) When the original assessment is completed u/s 143(3) and the reassessment proceedings have been initiated after a period of 4 years from the end of the relevant assessment year and there is no allegation of any failure on the part of the assessee to disclose fully and truly all […]

HC quashes Section 148 notice for failure to record reason for issue of notice

April 10, 2022 1302 Views 0 comment Print

Hariom Ingots and Power Pvt. Ltd. Vs PCIT (Chhattisgarh High Court) Perusal of aforementioned provisions under Section 56 of the I.T. Act would reflect that Section 56 mentions about the income from other sources. Section 56(vii) talks about the income received by an individual or a Hindu undivided family in any previous year. Petitioner is […]

HC quashes Reassessment Notice as reasons not existed on the date of notice

April 7, 2022 1659 Views 0 comment Print

Ashika Credit Capital Limited Vs Union of India And Ors. (Calcutta High Court) Mr. Roy Chowdhury, learned advocate appearing for the Revenue was asked to produce the record to establish that the recorded reasons were existing at the time of issuance of impugned notice under Section 148 and initiation of impugned assessment proceeding under Section […]

HC quashes Reassessment notice & Proceeding based on wrong premises

April 6, 2022 927 Views 0 comment Print

Realization Stock & Equity Pvt. Ltd. Vs. ITO (Calcutta High Court) One of the reasons for reopening of assessment is that no regular assessment under Section 143 (3) of the Act was made in the instant case and even in the last paragraph of the said reason again it has been recorded again that no […]

Reopening merely based on AIR information of Cash Deposit is not valid

April 3, 2022 8088 Views 0 comment Print

Udesh Sharma Vs ITO (ITAT Delhi) Admittedly in this case, the AO while recording reasons for selection of the case on the basis of AIR information observed that the Assessee has deposited cash of Rs. 44,00,500/- in his S.B. Account during the F.Y. 2008-09 and therefore issued a verification letter dated 30.10.2015 to the Assessee […]

Reassessment provisions framed under Finance Act, 2021 cannot be deferred by CBDT notifications: HC

April 3, 2022 963 Views 0 comment Print

Shweta Kedia Vs ITO (Rajasthan High Court) Issues: Whether after introduction of new provisions for reassessment of income by virtue of the Finance Act, 2021 with effect from 01.04.2021, substituting the then existing provisions, would the substituted provisions survive and could be used for issuing notices for reassessment for the past years and Whether the […]

Reopening based on vague & un-substantive reasoning not sustainable

March 31, 2022 1680 Views 0 comment Print

The reasons recorded in the instant case are vague and based on un-substantive reasoning, uncorroborated material and lack of evidence and hence as per decisions of the jurisdictional High Court referred above, the reasons referred above tantamount to be based on borrowed satisfaction and according to our considered view, does not sound valid reasons in the eyes of law, for reopening of the case.

Ressessment Invalid if no failure on the part of assessee to disclose fully & truly all material facts

March 29, 2022 849 Views 0 comment Print

P. Divagar Vs ITO (ITAT Chennai) n the present case, the only issue for consideration is whether the reopening of assessment under section 147 of the Act is valid or not. For the sake of convenience, the reasons recorded and communicated to the assessee are reproduced as under: “The assessee filed his return of income […]

Indiscriminate Income Tax notices without allowing reasonable time

March 20, 2022 12966 Views 0 comment Print

In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry and CBDT that suitable steps should be taken so that adequate time is allowed for compliance and cases are not disposed of in a hurry, without giving adequate opportunity for the taxpayer to be heard. The […]

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

March 20, 2022 41871 Views 2 comments Print

Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time barring as on 31.3.22 under the Income Tax Act 1961 in view of Problems faced in completion of Reopened Assessment cases (letting time barred on 31st March 2022, Problems faced in completion of Assessment as […]

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