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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 87 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


Reassessment Invalid If No Addition on Original Reason: ITAT Jaipur

October 30, 2025 555 Views 0 comment Print

The ITAT Jaipur ruled that an entire reassessment order must be quashed if the Assessing Officer (AO) makes no addition on the specific issue for which the case was reopened. Following the binding Rajasthan High Court precedent in Shri Ram Singh, the Tribunal held that the AO loses jurisdiction to assess unrelated, other escaped income (like LTCG) once the initial reason to believe is found to be incorrect.

ITAT Deletes LTCG Addition as “Human Probability” Can’t Replace Evidence

October 30, 2025 627 Views 0 comment Print

ITAT Delhi deleted a ₹47 lakh bogus LTCG addition, holding that ‘human probability’ cannot override transactions conducted through stock exchange, demat, and banking channels. Mere high profit does not make a transaction bogus.

Reassessment Quashed for Addition Based on Retracted Search Statements & missing DIN

October 30, 2025 795 Views 0 comment Print

Mumbai ITAT deleted a ₹4.20 lakh addition, quashing the reassessment because the addition was based solely on uncorroborated, retracted search statements and “dumb documents.” The tribunal ruled that once retracted, statements lose evidentiary value without independent verification.

No Second Guessing AO’s Judgment – ITAT Nullifies PCIT’s 263 Revision as Overreach

October 30, 2025 249 Views 0 comment Print

PCIT initiated a Section 263 revision over AO’s failure to disallow cash payments under Section 40A(3). ITAT held that since AO had conducted adequate inquiry and taken a plausible view, revision was an invalid overreach and quashed order. The ruling affirms that a mere difference in opinion doesn’t satisfy twin conditions for invoking Section 263.

Lower of book loss or unabsorbed depreciation to be set off against book profits as per section 115JB

October 30, 2025 990 Views 0 comment Print

ITAT Delhi held that as per the MAT provisions of section 115JB of the Income Tax Act the lower of book losses or unabsorbed depreciation can be set off against book profits. Accordingly, order of CIT(A) upheld and appeal of assessee dismissed.

Reassessment Quashed: Approval for Notice Beyond 3 Years Must Be PCCIT, Not PCIT

October 29, 2025 1233 Views 0 comment Print

ITAT Delhi nullified a reassessment, ruling that mandatory sanction under Section 151 was invalid because it was granted by Principal Commissioner (PCIT). Tribunal held that reopening assessments after three years requires approval from higher authority: Principal Chief Commissioner (PCCIT).

Search Assessment Barred: Limitation Period Starts When AO Gets Seized Papers

October 29, 2025 627 Views 0 comment Print

ITAT Delhi dismissed the Revenue’s appeal, ruling that the assessment under Section 153C was time-barred because the block period must be calculated from the date the Assessing Officer (AO) of the non-searched person received the seized material. The ruling confirms that the date of the original search is irrelevant for non-searched persons.

ITAT Delhi Deletes Penalty for Non-Compliance Where Notice Not Served on NRI

October 29, 2025 918 Views 0 comment Print

ITAT Delhi deleted a penalty levied under Section 272A(1)(d) against a Non-Resident Indian (NRI) for alleged non-compliance with a Section 142(1) notice.1 The court ruled that service of notice, not mere issuance, is mandatory, and lacking proof of service on the UK resident constituted a reasonable cause for non-compliance.

Revised Return After Detection Not Voluntary – ITAT Upholds 200% Misreporting Penalty

October 28, 2025 4866 Views 0 comment Print

ITAT Pune held that filing a revised return after the Department detects wrong deductions is not voluntary. Since the assessee acted only after detection, penalty u/s 270A(9) for misreporting was rightly imposed at 200% of tax.

Penny Stock Gains Upheld as Genuine – ITAT Quashes Reopening for Lack of Fresh Material

October 28, 2025 705 Views 0 comment Print

ITAT Pune held that reopening based on old investigation data was invalid where transactions were already verified under Section 153A. The Tribunal found the penny stock gains genuine as supported by Demat, bank, and STT records.

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