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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


Search Assessments Must Rely on Seized Material, Not Fishing Expeditions – Additions Quashed

November 4, 2025 405 Views 0 comment Print

ITAT Chennai deleted additions made in search assessments (u/s 153A), ruling that Income Tax Department cannot make additions without specific, incriminating material seized during search. Following Supreme Courts ruling in Abhisar Buildwell, Tribunal held that search assessments are not fishing expeditions and must be strictly limited to evidence found post-search.

ITAT Pune Deletes Perquisite Addition Already Included in Director’s Salary

November 4, 2025 288 Views 0 comment Print

Pune ITAT ruled against adding the perquisite value of rent-free accommodation, finding that the amount was already included and taxed as part of the directors’ disclosed salary.

Reassessment held invalid as approval u/s. 151 granted in mechanical manner

November 3, 2025 1647 Views 0 comment Print

ITAT Hyderabad held that reopening of assessment is invalid in as much as the approval/ sanction under section 151 of the Income Tax Act is granted in a mechanical manner. Further, reasons for reopening are based on on-application of mind and borrowed satisfaction. Accordingly, reopening quashed and appeal allowed.

Section 69A Addition Unsustainable When Sales Already Taxed: ITAT Ahmedabad

November 2, 2025 1032 Views 0 comment Print

ITAT Ahmedabad ruled that once sales have been recorded and taxed, they cannot again be treated as unexplained income under Section 69A, deleting addition made on alleged accommodation entries.

ITAT Delhi Quashes Reassessment for AY 2015-16 as Notice Issued Beyond Limitation Period

November 2, 2025 873 Views 0 comment Print

The ITAT Delhi allowed the appeal of Sunita Salhotra, quashing the Section 148 notice for AY 2015-16 as barred by the statutory limitation period that expired on March 31, 2022. The Tribunal relied on the Revenue’s concession in the Supreme Court’s Rajiv Bansal case regarding notices issued for this AY on or after April 1, 2021.

ITAT Pune Restricts Profit Estimation to 1.5% in Poultry Transporter’s Case

November 2, 2025 546 Views 0 comment Print

ITAT Pune held that assessee was engaged in livestock transport on commission basis and not in trading, directing AO to apply 1.5% profit rate instead of 8% estimated earlier.

ITAT Restricts Section 56(2)(vii)(b) Addition to 50% for Joint Property Purchase

November 2, 2025 411 Views 0 comment Print

ITAT restricted the addition under Section 56(2)(vii)(b) to 50% on a jointly purchased property, preventing double addition as the co-owner was already taxed on the balance.

ITAT Orders Fresh Verification of Unexplained Russian Remittances in Alleged Over-Invoicing Case

November 2, 2025 168 Views 0 comment Print

ITAT Delhi remanded the case for re-examination of foreign remittances from Russia, directing the Assessing Officer to verify if the receipts were genuine trade receivables amid allegations of over-invoiced exports.

Approval from PCIT Instead of PCCIT Invalidates Section 148 Notice: ITAT Pune

November 2, 2025 972 Views 0 comment Print

ITAT Pune annulled reassessment proceedings, holding that approval by PCIT instead of PCCIT for notices issued after three years was contrary to Section 151.

ITAT Delhi Upholds Deletion of ₹22.38 Cr Interest Disallowance – Advances Held Business-Driven

November 2, 2025 552 Views 0 comment Print

The Tribunal ruled that the assessee had sufficient interest-free funds (own capital and unsecured loans) to cover the advances given, thus breaking the presumed nexus with interest-bearing funds. This decision reinforces the principle that disallowance is impermissible when the taxpayer possesses adequate non-interest-bearing capital for making advances.

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