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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


Order passed by AO in old PAN cannot be survived if transactions already reported in new PAN

September 30, 2025 573 Views 0 comment Print

ITAT Hyderabad held that assessment order passed by AO in old PAN cannot be survived if transactions reported by DGFT in old PAN is already reported by assessee in new PAN. Accordingly, matter restored back to re-verify.

Section 148 Notice Beyond 7-Day Grace Period Void: ITAT Delhi Quashes Reassessment

September 29, 2025 1065 Views 0 comment Print

The ITAT Delhi quashed the reassessment against Lombard Portfolio Pvt. Ltd., ruling the Section 148 notice was time-barred. Following the Supreme Court’s mandate in the Ashish Agarwal case.

Reopening Beyond 10 Years Void: ITAT Delhi Quashes ₹2.25 Cr Assessment

September 29, 2025 876 Views 0 comment Print

ITAT Delhi rules that reassessment beyond 10 years is void, holding satisfaction note date governs limitation; ₹2.25 Cr addition for AY 2012-13 deleted.

Saif Ali Khan Wins Tax Appeal as ITAT Mumbai Strikes Down Defective Reassessment

September 28, 2025 552 Views 0 comment Print

The ITAT Mumbai quashed the reassessment notice against Saif Ali Khan (AY 2016-17), holding the AO improperly obtained approval from the Pr. CIT instead of the Pr. CCIT for reopening beyond the three-year limit.

Free Flat Receipt Not Taxable in AY 2007-08: Section 56(2)(v) Covered Only Money

September 28, 2025 393 Views 0 comment Print

ITAT Mumbai ruled that the allotment of a flat to the assessee during AY 2007-08 does not attract tax under Section 56(2)(v), as the provision at that time applied only to money received, not immovable property.

ITAT Delhi Allows Section 54F Exemption to Private Trust on Capital Gains

September 28, 2025 5886 Views 0 comment Print

Delhi ITAT confirms that a private trust with identifiable beneficiaries is eligible for the capital gains exemption under Section 54F, similar to an individual.

ITAT Ahmedabad Deletes Addition for Unexplained Investment in Property for Retired Government Employee

September 28, 2025 504 Views 0 comment Print

Somabhai Mohandas Patel Vs ITO (ITAT Ahmedabad) The case of Somabhai Mohandas Patel vs. ITO before the Income Tax Appellate Tribunal (ITAT) in Ahmedabad involved an appeal by a taxpayer, Somabhai Mohandas Patel, against an order passed by the National Faceless Appeal Centre (NFAC) upholding the addition of ₹10,33,012 to his income. This addition was made […]

Suspicion Alone Cannot Trigger Reassessment: ITAT Delhi on Validity of 147 Notice

September 28, 2025 408 Views 0 comment Print

ITAT Delhi ruled that an AO’s belief based on incorrect assumptions—such as the non-filing of a return—cannot form a valid basis for reopening. Cash deposits fully disclosed in audited accounts were held legitimate.

ITAT Restricts Tax on Bank Deposits to Peak Credit – Full Cash Not Taxable

September 28, 2025 936 Views 0 comment Print

Bangalore ITAT restricted the s.69A unexplained cash addition for non-filer Umesh Babu to the peak credit of Rs.12.25 lakhs, rejecting the Rs.ケ57.10 lakhs addition.

ITAT Jaipur Denies Charitable Exemption Over Misuse of Cloth Merchant Trust Funds

September 28, 2025 486 Views 0 comment Print

The ITAT Jaipur dismissed the appeals of Whole Sale Cloth Merchant Association, upholding the reassessments and denial of Section 11/12 exemption. The Tribunal confirmed that the trust’s failure to file returns

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