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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 6015 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 1671 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 927 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 63 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 42 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 666 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 156 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 264 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


Section 263 revision against void-ab-initio order or against a non-existent entity

September 15, 2020 3195 Views 0 comment Print

Revision under section 263 by the Principal Commissioner or Commissioner against void-ab-initio order or against a non-existent entity If an order is passed by the Assessing Officer against a non-existent entity, e.g. against an Amalgamating Company or against a Dissolved Firm, such an order is void-ab-initio and no revision can be made under section 263 against such […]

Depreciation charge must to Claim Section 80IB Deduction

September 13, 2020 675 Views 0 comment Print

whether depreciation is mandatory to be granted while determining the Appellant’s entitlement to the deduction under Section 80IB of the Act, even though the Appellant had not claimed such depreciation?

Assessment cannot be reopened u/s 147 Based on Material Assessed by AO in Original Assessment

September 11, 2020 957 Views 0 comment Print

The issue under consideration is whether reopen assessment u/s 147 based on the same material which is examined by AO in original assessment is justified in law?

Reopening of Assessment for mere Difference in Valuation Report Not Justified

September 7, 2020 2850 Views 0 comment Print

The issue under consideration is whether the issue of notice u/s 147 for re-opening of assessment on the basis of difference in valuation report is justified in law?

Reopening to assess Income under different head due to change of opinion is invalid

August 31, 2020 1134 Views 0 comment Print

Reopening of assessment to assess the remuneration under the head ‘income from salary’ instead of ‘income from other sources’ constitutes difference of opinion and the AO is not permitted to reopen the assessment on difference of opinion

Section 148 Notice to Legal heirs after expiry of limitation period is invalid

August 27, 2020 9252 Views 0 comment Print

Sh. Shambhu Dayal, Ravi Dutt, Gori Shankar Rajesh Rohit L/h Late Sh. Jhabar Mal (ITAT Jaipur) The undisputed facts are that the assessee, Shri Jhabar Mal Kumawat had expired on 10.10.2015 as noted by the AO in the assessment order. Thereafter, the reasons for reopening the assessment u/s 147 were recorded and after seeking approval […]

Second Re-Assessment Notice Issued against Johnson & Johnson is Rejected by ITAT

August 25, 2020 822 Views 0 comment Print

The issue under consideration is whether the re-opening of assessment u/s 147 of the Act is justified in law?

No addition for other items if addition for reopening of reassessment not survives

August 19, 2020 1116 Views 0 comment Print

Naresh Kumar Garg Vs ACIT (ITAT Delhi) When the grounds for reopening the reassessment do not exist any longer and no additions were ultimately made on that account, the addition in respect of the other items, which were not part of the ‘ reasons to believe’cannot be made. ITAT states that it is evident that […]

Reopening of Assessment for Mere Change of Opinion is unjustified

August 12, 2020 1998 Views 0 comment Print

Whether the Tribunal was justified in holding that the reopening of assessment was a result of mere change of opinion, even when there is no opinion formed or expressed by the Assessing Officer on this issue in the original assessment?

Onus on Revenue to prove Assessee Paid Donation to College in Cash

August 12, 2020 990 Views 0 comment Print

The issue under consideration is whether the addition made by AO merely based on the statement recorded under section 132(4) of the I.T. Act is justified in law?

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