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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 proceedings u/s. 147 cannot be sustained in absence of valid service of notice

October 3, 2025 873 Views 0 comment Print

Allahabad High Court held that in absence of valid service of notice under section 148 of the Income Tax Act, proceedings under section 147 of the Income Tax Act for reassessment cannot be initiated. Accordingly, appeal of the assessee allowed.

Assessment u/s. 153A quashed as no incriminating material found during search

October 3, 2025 678 Views 0 comment Print

Karnataka High Court held that no incriminating material was found during the search proceedings and therefore no reassessment of income for the relevant assessment year could be made under Section 153A of the Income Tax Act. Accordingly, appeal of revenue dismissed.

ITAT Rajkot Deletes Unexplained Cash Addition for Senior Citizen Citing CBDT Limit

October 3, 2025 1017 Views 0 comment Print

ITAT Rajkot deletes Rs.2.5 lakh cash addition made during demonetization, ruling that the amount was within the non-taxable limit specified by the CBDT for small deposits.

ITAT Delhi Quashes Reassessment Where No Addition Made on Recorded Reasons

October 3, 2025 1266 Views 0 comment Print

ITAT Delhi quashes reassessment, deleting Rs. 85 lakh Sec 69C addition. AO cannot travel beyond recorded reasons if the original reason for reopening is not sustained.

Rs. 3.50 Cr Bogus Loan Addition: ITAT Delhi Quashes Reassessment Over Wrong PAN & Mechanical Approval

October 3, 2025 570 Views 0 comment Print

ITAT Delhi held that reopening under Section 148 on an incorrect PAN and with mechanical sanction by PCIT is invalid, quashing the Rs. 3.50 crore addition under Section 68 and setting aside reassessment proceedings.

Section 56(2)(vii) Not Applicable on Leasehold Properties – ITAT Delhi

October 1, 2025 1050 Views 0 comment Print

ITAT held that provisions taxing difference in stamp value and purchase price apply only to land and buildings, not leasehold rights. Addition of ₹21.95 lakh was set aside.

Reassessment u/s. 147 without any fresh and new material is invalid

October 1, 2025 870 Views 0 comment Print

ITAT Indore held that reopening of assessment done by Assessing Officer under section 147 of the Income Tax Act, based on tax audit report already available during original assessment, without any fresh and new material is invalid and liable to be quashed.

ITAT Chennai Upholds Deletion of ₹2 Crore Loan Addition – Loan Already Taxed in Borrower’s Hands

October 1, 2025 327 Views 0 comment Print

ITAT Chennai holds that ₹2 crore loan cannot be added as unexplained investment in lender’s case when already offered before Settlement Commission by borrower.

ITAT Orders Fresh Hearing on Unexplained Cash Deposits of ₹1.49 Cr & Peak Credit Method

October 1, 2025 462 Views 0 comment Print

Bangalore ITAT restored a case involving Rs.1.49 crore in unexplained cash deposits for fresh assessment, directing the AO to re-examine the source and the CIT(A)’s application of the peak credit method.

Execution of Joint Development Agreement doesn’t constitute transfer of capital asset

September 30, 2025 1572 Views 0 comment Print

ITAT Chandigarh held that execution of Joint Development Agreement [JDA] doesn’t constitute transfer of capital asset which would result in earning of capital gain. Accordingly, addition is deleted and appeal is allowed.

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