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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


ITAT Ahmedabad quashes 263 revision – AO had made detailed enquiry into penny stock LTCG claim

October 13, 2025 375 Views 0 comment Print

The ITAT Ahmedabad set aside the PCIT’s revisionary order under Section 263, ruling that the AO’s acceptance of ₹12.18 lakh exempt LTCG on Kushal Tradelink shares was based on a detailed inquiry and a plausible view. The Tribunal held that revision is invalid when the AO conducts due diligence, finds no adverse material to link the assessee to price rigging, and takes a possible view on the evidence.

Tax Audit Exception: ITAT Confirms Interest is Not “Gross Receipts” for 44AB and Deletes Penalty

October 13, 2025 300 Views 0 comment Print

The ITAT Delhi allowed the appeal because the penalty under Section 271A for non-maintenance of books had already been deleted by the Tribunal, establishing that the authority was not legally obliged to keep books. The Tribunal concluded that if no books are required to be maintained under Section 44AA, no penalty for failure to audit them under Section 271B can legally survive.

ITAT Ahmedabad Slams Suspicion: Addition Deleted After Assessee Proves Loan Source with Land Sale Deed and Confirmations

October 13, 2025 321 Views 0 comment Print

The Tribunal directed the deletion of the balance unexplained cash credit, emphasizing that mere suspicion of cash deposits in the lenders account doesnt negate the genuineness of a loan when the lender has significant proven sources like an agricultural land sale.

Bogus LTCG Allegation: ITAT Remands ₹2.28 Cr Addition as AO Failed to Independently Verify Evidence

October 13, 2025 222 Views 0 comment Print

The ITAT Ahmedabad set aside the addition of ₹2.28 crore LTCG, holding that the Assessing Officer failed to conduct any independent inquiry or verify the assessees documentary evidence before treating the gain as bogus. The Tribunal restored the case, emphasizing that an allegation of penny stock misuse cannot be sustained merely on third-party information without a proper, on-merits examination of the assessees documentation.

Mere Suspicion Not Enough: ITAT Deletes LTCG Addition on Kushal Tradelink Shares for Lack of Concrete Proof

October 13, 2025 798 Views 0 comment Print

The Tribunal set aside the addition of LTCG and commission under Section 69C, affirming that the Revenue cannot deny exemption under Section 10(38) based on a general investigation into Kushal Tradelink without establishing the assessees direct involvement in the accommodation entries. This ruling confirms that once the assessee discharges the initial burden of proof, the Revenue must provide contrary material to sustain the addition.

ITAT Hyderabad Condonation of Delay: Appeal Restored After NFAC Sent Notices to Wrong Email

October 13, 2025 354 Views 0 comment Print

In a key ruling, ITAT Hyderabad restored an appeal that the CIT(A) had dismissed for non-prosecution, as the NFAC was found to have incorrectly used an email address other than the one specified by the assessee in Form 35. The Tribunal followed the Supreme Courts mandate for a liberal approach to condoning the resulting 98-day delay and remanded the case for a decision on merits.

Section 69A matter remanded back as additional evidences needs verification of lower authority

October 13, 2025 459 Views 0 comment Print

ITAT Hyderabad held that addition towards unexplained money under section 69A of the Income Tax Act is liable to be set aside and matter is remanded back to AO since additional evidences submitted by the assessee needs to be verified by lower authorities.

Reassessment Notice Quashed for Lack of Proper Sanction under Section 151

October 13, 2025 2208 Views 0 comment Print

ITAT Jaipur quashed the reassessment order against Late Shri Jitendra Nagar, ruling the AO used the wrong authority (PCIT) for sanction under Section 151(ii), following the Supreme Court’s Rajeev Bansal precedent.

AO Cannot Reopen Assessment U/s. 147 Before 143(2) Period Expires: ITAT Mumbai

October 11, 2025 816 Views 0 comment Print

The ITAT Mumbai ruled that the power to reopen an assessment under Section 147/148 is invalid when a valid return is on record and the Assessing Officer still has time to initiate regular scrutiny under Section 143(2).

Notice issued within time but Served After Limitation Period Voids Reopening: ITAT Kolkata

October 11, 2025 432 Views 0 comment Print

Relying on the jurisdictional High Court precedent, the Tribunal quashed the entire crore addition, holding that service of the notice beyond the statutory limitation date is a fatal flaw. The decision emphasizes that procedural compliance with the time limit is mandatory and cannot be waived.

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