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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 Delhi Deletes ₹27 Crore Income Tax Addition on Farmhouse Sale, Cites Flawed Reassessment Proceedings

September 25, 2025 645 Views 0 comment Print

The Income Tax Appellate Tribunal (ITAT) Delhi has set aside a significant tax addition against Maple Destinations, ruling that the reassessment was based on uncorroborated, retracted statements and a denial of the assessee’s right to cross-examination, which violated principles of natural justice.

Charter Hire Charges: Royalty or Section 44BB Income? Mumbai Tribunal Orders DRP to Reconsider

September 25, 2025 366 Views 0 comment Print

ITAT Mumbai set aside DRP directions for Celestial Vision Ltd, ruling the DRP mixed up facts, failed to address 44BB applicability, and mistakenly discussed Section 147 reopening procedures.

No notice should be issued under Section 148A(b) in absence of undeclared/unexplained income

September 25, 2025 1251 Views 0 comment Print

In the instant case, the grievance of assessee was directed against the impugned notices dated 24.03.2025 and 28.05.2025 issued under Section 148A(1); the order passed under Section 148A(3); and the consequential notice issued under Section 148, all pertaining to AY 2019-20.

Delhi ITAT Quashes Reopening – Two Different Reasons & Post-Facto Approval Fatal

September 25, 2025 765 Views 0 comment Print

The ITAT Delhi has set aside the reassessment of Avon Containers, ruling the Income Tax Department’s notice void.

Reassessment Confirmed, Rs. 2.01 Crore Capital Gain Addition Sent for Fresh Valuation

September 25, 2025 1068 Views 0 comment Print

ITAT Ahmedabad upheld reopening of assessment for undisclosed high-value property sale, but remanded the Rs. 2.01 crore capital gain for fresh valuation due to flawed valuation reports.

Reassessment Based on Third-Party Laptop Data Remanded for Fresh Hearing

September 25, 2025 432 Views 0 comment Print

The Tribunal condoned a 376-day delay in filing the appeal, citing a consultant’s lapse, and ruled that the assessee was denied a fair hearing. The case was remanded for a detailed examination of jurisdictional and factual issues.

General Modus Operandi Insufficient – Labour Expenses & Unsecured Loans Held Genuine

September 25, 2025 297 Views 0 comment Print

Tribunal rules that allegations based on generalized survey findings and third-party statements cannot sustain additions. Labour expenses and unsecured loans routed through banking channels were confirmed as genuine, with revenue appeals dismissed.

Loan routed through banking channels & repaid with interest & TDS – Section 69A Addition deleted

September 24, 2025 453 Views 0 comment Print

ITAT Ahmedabad confirmed that the unsecured loan of ₹80.94 lakh given by Mahadev Shipbreakers to KCPL was genuine, routed through banking channels, and repaid with interest and TDS. The Tribunal dismissed Revenue’s appeal, noting AO’s allegations were generalized and unsubstantiated.

Mumbai ITAT Deletes ₹7 Lakh Section 69 Addition for Non-Resident Assessee

September 24, 2025 651 Views 0 comment Print

ITAT Mumbai deleted a Rs.7 lakh addition made to a non-resident Indian, ruling that his explanation for property investment was plausible, with funds sourced from NRE account withdrawals and jewelry sales.

ITAT Nagpur Quashes PCIT’s 263 Revision: Protective Addition Cannot Be Substituted

September 24, 2025 318 Views 0 comment Print

PCIT’s revision order on Gajanand Financial Consultancy’s protective addition was quashed by ITAT Nagpur. The Tribunal ruled the AO made a detailed enquiry, and protective additions can’t be revised when substantive ones exist.

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