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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


Premature or Time-Barred Section 143(2) Notices Invalidate Assessment: ITAT Mumbai

October 11, 2025 852 Views 0 comment Print

The ITAT set aside the entire reassessment, holding that a valid notice is a mandatory jurisdictional step, citing the Supreme Court’s Hotel Blue Moon ruling. Since the two notices issued were defective (one premature, the other beyond the statutory time limit), the assessment was deemed illegal.

ITAT Upholds Deletion of Bogus F&O Loss Additions; Post-Search Reports Cannot Justify 153A

October 11, 2025 624 Views 0 comment Print

Mumbai ITAT affirmed the deletion of a ₹2.74 crore F&O loss addition under Section 153A for an unabated year. The addition, based only on the post-search “Project Falcon” report, was void as no incriminating material was found during the search itself, following the Supreme Court’s mandate.

ITAT Delhi delivers a two-fold relief – quashes reassessment as void for lack of jurisdiction & grants full Section 54F exemption even where houses are constructed in son’s name

October 11, 2025 357 Views 0 comment Print

The ITAT quashed the reassessment order as void because the final assessment was completed by an Income Tax Officer (Ward-2) who lacked jurisdiction, while the proceedings were initiated by another officer (Ward-3). The Tribunal, citing the Allahabad High Court, ruled that jurisdiction cannot be waived or conferred by participation.

ITAT Chennai restricts addition on cash deposits – Treats assessee as commission agent, estimates income at 4% instead of taxing entire deposits

October 11, 2025 540 Views 0 comment Print

he ITAT restricted a S.69A addition on ₹1 crore cash deposits, ruling that treating the entire gross receipt as unexplained income was unjustified for a commission agent. Considering the low-margin onion trading business and past assessments, the Tribunal estimated 4% of the deposits as the correct taxable commission income.

Notice u/s 148 After 3 Years Needs Pr.CCIT Approval – ITAT Says Sanction by Pr.CIT Invalid, Reopening Quashed

October 11, 2025 789 Views 0 comment Print

The ITAT Chennai upheld the quashing of a reassessment for AY 2017-18, ruling the u/s 148 notice invalid. As more than three years had elapsed, u/s 151(ii) required sanction from the Principal Chief Commissioner (Pr.CCIT), not the Principal Commissioner (Pr.CIT), confirming the jurisdictional defect.

AO Accepted Agri Income in Next Year but Denied in Earlier Year Without Logic – ITAT Deletes Addition as CIT(A) Adopted “Whims & Fancies”!

October 11, 2025 282 Views 0 comment Print

The ITAT deleted the addition, ruling the CIT(A)’s rejection of agricultural income based solely on bank deposits not tallying bill-to-bill was arbitrary and illogical. Once the genuine agricultural activity was accepted, timing differences or cash accumulation must be considered.

ITAT Ahmedabad: Reassessment Annulled as Notice u/s 148 Issued Beyond Surviving Limitation Period — Invalid under Rajeev Bansal & TOLA Framework

October 11, 2025 1044 Views 0 comment Print

The ITAT Ahmedabad annulled reassessment proceedings as the notice under Section 148 was issued beyond the surviving limitation period prescribed under TOLA and clarified in Rajeev Bansal (SC).

No addition u/s. 43CA as difference between sale price and DVO valuation within tolerance band

October 10, 2025 726 Views 0 comment Print

ITAT Nagpur held that addition under section 43CA of the Income Tax Act unwarranted since difference between actual sale price and valuation as per DVO is within tolerance band of 10%. Accordingly, entire addition is directed to be deleted.

Additions Based on Bank Credits Without Verification Unjustified – CIT(A)’s Factual Findings Upheld

October 10, 2025 504 Views 0 comment Print

The ITAT Hyderabad in ITO Vs. SR Peddi Estates India Pvt. Ltd. confirmed the deletion of a ₹4.39 crore addition made during reassessment. The Tribunal ruled that bank credits

No Capital Gains Tax on JDA Execution Until Land Possession Is Handed Over

October 10, 2025 1377 Views 0 comment Print

The Tribunal held that capital gains did not arise in the relevant year because the JDA explicitly stated possession was deemed given only upon handing over the landowners’ built-up share. This means Section 45(1) cannot be invoked until actual possession or consideration is received, overriding the AO’s reliance on stamp duty valuation.

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