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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 5946 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 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 54 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 39 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 582 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 153 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 222 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


Reasons Based on Material Already Available on Record Invalidates Reopening

August 8, 2021 2142 Views 0 comment Print

DCIT Vs Paveljeet Singh Ruppal (ITAT Delhi) The Assessing Officer has to demonstrate from the records that there has been a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. Here in this case, the assessee has duly disclosed the factum of total secured loan, total […]

Lack of fresh tangible material invalidates reopening when details already given in regular assessment

August 8, 2021 1572 Views 0 comment Print

ACIT Vs Sahyog Infrastructure Pvt. Ltd (ITAT Delhi) Based on the above reasons recorded, notice under Section 148 of the act was issued to the assessee on 25th of June, 2013. From the above reasons recorded it is evident that all these documents were available with the ld. Assessing Officer at the time of making […]

No section 263 revision could be made for order of reassessment

August 6, 2021 6819 Views 0 comment Print

Any order of the subordinate authority which could have been considered as erroneous and prejudicial to the interest of revenue in allowing assessee’s claim of deduction under section 80IA, either due to lack of enquiry or otherwise, was the original assessment order passed under section 143(3) r.w.s. 144C and not the re-assessment order. PCIT had proceeded to revise the assessment order passed under section 143(3) r.w.s. 147 to get over the hurdle of limitation which was impermissible.

Assessment order valid despite initial section 147 notices in wrong name if revenue identifies & corrects the mistake

August 1, 2021 3255 Views 0 comment Print

Principal Officer, M/s. Vedanta Limited Vs DCIT (Madras High Court) As far as the present Writ Petition is concerned, admittedly, the notice under Section 148 was issued in a wrong name. However, close reading of the name of the Company would reveal that the first word ‘Sesa’ is not alien to the petitioner Company and […]

Section 147: Revenue to prove failure of Assessee in Full & True Disclose of All Material Facts

August 1, 2021 2688 Views 0 comment Print

PCIT Vs Superior Films Private Limited (Delhi High Court) When the assessee has filed a return u/s 139 of the Act or in response to sections 142(1) or 148 of the I.T.Act and when an assessment order u/s 143(3) or u /s 147 of the Act has already been passed then the assessee enjoys statutory […]

Reopening assessment under Section 148 without recording reasons is bad in law

July 29, 2021 3480 Views 0 comment Print

In present facts of the case, it was observed that in the absence of  reasons, the jurisdiction assumed under section 148 of the Act to reopen a completed assessment is clearly void ab initio and consequently, assessment order is bad in law.

Reassessment valid as AO formed prima facie opinion for escapement of income

July 29, 2021 957 Views 0 comment Print

Electrotherm (India) Ltd. Vs DCIT (ITAT Ahmedabad) Conclusion:  Since AO after applying his mind on information received from VAT Department arrived at the conclusion, based on the reasons to believe that income of assessee had escaped assessment. and at the time of issuing notice under section 148 AO had formed prima facie opinion for escapement […]

New scheme for re-assessment u/s 147 of the Act wef 1.4.2021

July 27, 2021 16314 Views 1 comment Print

Section 147 has been Amended vide Finance Act 2021. Information is required by AO for reopening not “Reasons to believe” If any income chargeable to tax, in the case of an assesses, has escaped assessment for any assessment year. The assessing office may, subject to the provisions of Section 148 to 153, assess or re-assess […]

Powers/Jurisdiction of Assessing Authorities for Reassessment u/s 147

July 21, 2021 2415 Views 0 comment Print

Aban Offshore Limited Vs Addl. CIT (Madras High Court) Case Summary: – Facts of the case: ♦ The Assessee, Aban Offshore Limited, engaged in providing oil field services to various oil majors for offshore exploration and production of hydrocarbons in India and abroad, is a regular Assessee in terms of the provisions of the Indian […]

AIR information of cash deposit with Bank – Section 147 Notice reply

July 15, 2021 17583 Views 0 comment Print

Applicability of Section 147 read with explanation 2(b) on the basis of AIR information regarding cash deposit with the Bank. Written Submission before the Hon’bleCIT(A), Faceless in respect of Sh. XXXXXXXXXXXXXX for the A.Y. 2012-13 [XXXXXXXXXXXXX] Appeal filed against the order of assessment u/s 144 made by ITO, Ward No. 2 (5), XXXXXXXXXXX dated 30.11.2019 […]

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