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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


Assessment Order in Deceased Assessee’s Name Not Sufficient to Quash Proceedings

October 25, 2025 561 Views 0 comment Print

ITAT Chandigarh ruled that a CIT(A) order is not void simply because it names the deceased assessee. The Tribunal restored the case, directing the CIT(A) to admit evidence due to the assessee’s prior illness.

ITAT Delhi Deletes 25% “Bogus Sales” Disallowance; Section 37 Not Applicable to Sales

October 24, 2025 954 Views 0 comment Print

ITAT Delhi held that sales made to Jyoti Products were genuine, supported by ledgers and invoices. The 25% disallowance by the AO under Section 37 was deleted, as Section 37 applies only to business expenditure, not sales transactions.

Unexplained money u/s. 68 restored back as basic ingredients satisfactorily not explained

October 24, 2025 492 Views 0 comment Print

ITAT Raipur held that matter regarding unexplained money addition under section 68 of the Income Tax Act restored back as basic ingredients required u/s 68, i.e., identity / creditworthiness of the investors and genuineness of transactions not satisfactorily explained.

ITAT Quashes 263 Order as PCIT Withheld Adverse Material & Ignored Evidence of Genuine Purchases

October 24, 2025 507 Views 0 comment Print

The ITAT ruled that the PCIT wrongly invoked Section 263 by relying on unverified external information (e.g., SEBI data and license suspension claims) to label purchases as bogus, without providing this information to the assessee for rebuttal. The tribunal deleted the revisionary order, confirming that the PCIT acted illegally by presuming facts and ignoring the documentary proof of purchase genuineness.

“Dumb Documents” Seized from Third Party Cannot Justify Income Addition

October 24, 2025 909 Views 0 comment Print

The Tribunal followed the Supreme Court’s V.C. Shukla principle, reaffirming that loose papers seized from third parties are without evidentiary value unless properly linked to the assessee through verified facts. ITAT, therefore, quashed both the 69A addition and the underlying 147 reopening as being based on mere surmises and conjectures.

Addition Based on Retracted Third Party Statement Without Cross-Examination Invalid

October 24, 2025 546 Views 0 comment Print

The ITAT Mumbai held that the denial of the right to cross-examine a third party whose statement forms the foundation of a tax addition constitutes a serious violation of natural justice, citing the Supreme Court. The Tribunal set aside the 68 additions of 1.56 crore (across two years) and remanded the case to the AO for de novo assessment with mandatory opportunity for cross-examination.

Madras HC grants stay on recovery; keeps matter pending awaiting SC verdict in Hexaware case

October 24, 2025 708 Views 0 comment Print

Madras High Court granted an interim stay on all recovery proceedings initiated by the Income Tax Department against the reassessment order. The Court explicitly linked its decision and the case’s future to the Supreme Court’s forthcoming ruling in Hexaware Technologies, establishing a clear procedural precedent for similar reassessment writ petitions.

Rubber-Stamp Approval of 246 Assessments Struck Down by Delhi HC

October 24, 2025 516 Views 0 comment Print

This decision reinforces the legal requirement that supervisory approval under Section 153D is a substantive safeguard, not an empty ritual. The High Court affirmed that granting blanket sanction to 246 assessments through a generic endorsement is equivalent to a mechanical approval that fails to satisfy legislative intent.

Reopening Based Only on ACB Report: ITAT Quashes All 147 & 263 Orders

October 24, 2025 762 Views 0 comment Print

The Ahmedabad ITAT has struck down reassessment orders against Arpanbhai Virambhai Desai, holding that the AO’s reliance solely on an ACB disproportionate assets report without independent application of mind or specifying escaped income is “borrowed satisfaction,” invalidating the Section 147 jurisdiction.

ITAT Confirms ₹36.59 Cr Addition for Bogus Sale of Shops via Accommodation Entry

October 24, 2025 258 Views 0 comment Print

The Income Tax Appellate Tribunal (ITAT), Delhi, upheld the addition of ₹19.06 Cr (AY 2011-12) and ₹17.53 Cr (AY 2012-13) to Raheja Developers Limited’s income. The ITAT confirmed the finding that the sale of 22 shops to M/s Sagar Trade Links Pvt. Ltd. (STPL) was a bogus transaction involving a shell company to route the developer’s own unaccounted funds back into its books as sale consideration.

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