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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


Reassessment Set Aside for Fresh Hearing – Assessee Can Challenge Validity of Notice u/s 148 in Subsequent Proceedings: ITAT Hyderabad

October 10, 2025 1194 Views 0 comment Print

ITAT Hyderabad upholds remand for ex-parte reassessment, allowing the assessee to challenge the Section 148 notice validity based on the mandatory faceless procedure violation in fresh proceedings.

ITAT Ahmedabad: Addition on Alleged Penny Stock Investment Deleted – No Proof of Assessee’s Own Funds

October 10, 2025 402 Views 0 comment Print

ITAT Ahmedabad deletes Rs.11.27 lakh addition for penny stock investment, ruling the Revenue failed to prove the investment originated from the assessee’s own unexplained funds under Section 69B.

No hearing, no justice – ITAT Pune remands ex-parte CIT(A) order for fresh adjudication

October 10, 2025 522 Views 0 comment Print

ITAT Pune sets aside NFAC’s ex-parte order, mandating fresh adjudication on S. 44AD applicability to commission income, citing violation of natural justice and lack of proper notice.

When no addition on reopening issue, entire 147 proceeding falls JAO had no jurisdiction post-Faceless Scheme

October 10, 2025 1122 Views 0 comment Print

ITAT Hyderabad in Pitti Holdings Pvt. Ltd. vs ACIT quashes a reassessment for the Assessment Year 2018-19. The order holds that notices issued by the Jurisdictional AO (JAO) instead of the Faceless AO (FAO) after the Faceless Jurisdiction Scheme 2022 are void ab initio.

Faceless means faceless – ITAT Hyderabad quashes reassessment by local AO as void- JAO had no power post-2022 Scheme

October 10, 2025 798 Views 0 comment Print

The ITAT Hyderabad ruled that reassessment notices under Sections 148A(b) and 148 issued by the Jurisdictional Assessing Officer (JAO) after April 1, 2022, are invalid and void ab initio. This decision reinforces the mandatory nature of the Faceless Jurisdiction Scheme, 2022, quashing the entire reassessment for lack of proper authority.

Protective additions without substantive foundation quashed – ITAT Visakhapatnam invalidates reopening based on suspicion

October 10, 2025 561 Views 0 comment Print

The ITAT Visakhapatnam ruled that protective additions made in reassessment proceedings are invalid because they did not co-exist with a substantive addition for the same assessment year. The Tribunal held that a protective assessment cannot stand in isolation and cannot be based on mere suspicion to keep a hypothetical option open for the Revenue.

ITAT Quashes Reassessment: Escaped Income Below Rs. 50 Lakh Bars Extended Time Limit Reason

October 10, 2025 1881 Views 0 comment Print

This decision strengthens the protection against time-barred reassessment, emphasizing that the extended limitation under Section 149(1)(b) applies only if the escaped income is factually above ₹50 lakh. The ITAT confirmed the reassessment was invalid as the AO’s final order confirmed the escaped income was much lower than the extended limit required for reopening

No Retrospective Remand: ITAT Scraps CIT(A)’s Order in Bogus LTCG Case for Wrongly Invoking New Law

October 10, 2025 639 Views 0 comment Print

The ITAT ruled that the CIT(A) cannot set aside a reassessment order framed under Section 147 read with Section 144B, as the limited power to remand only applies to best-judgment assessments under Section 144. The Tribunal sent the penny stock LTCG case back, directing the CIT(A) to decide the appeal strictly on its merits.

Reopening u/s 147 quashed – AO’s “fishing enquiry” to investigate offshore receipts not valid formation of belief- Reassessment void where AO reopens only to verify PE/offshore claims

October 9, 2025 741 Views 0 comment Print

The ITAT Delhi invalidated the reassessment proceedings against Huawei International, a Singapore resident, for AY 2014-15. The Tribunal ruled that the AO’s attempt to investigate offshore software receipts, based merely.

ITAT Delhi remands ₹16.10 Cr unsecured – loan issue for verification; consequential interest disallowance also to be re-examined – CIT(A) erred in bypassing remand report

October 9, 2025 402 Views 0 comment Print

The ITAT Delhi set aside the CIT(A)’s order deleting a Rs.16.10 Cr unsecured loan addition against Nitin Garg, remanding the issue to the AO. The Tribunal found the CIT(A) erred by not requesting a remand report to verify the lender’s creditworthiness and the source of funds, despite the assessee’s non-compliance during assessment.

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