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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 2841 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 69 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 105 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 96 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 90 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 447 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 5742 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 Mumbai Accepted Ignorance & Accountant’s Default as Sufficient Cause for Delay in Appeal Filing

March 25, 2026 474 Views 0 comment Print

The Tribunal examined whether delay in filing appeal was justified under section 249(3). It held that sufficient cause must be interpreted liberally to ensure justice. The key takeaway is that technical delays should not deny statutory appeal rights.

Addition Deleted as Gross Receipts Cannot Be Taxed Without Profit Determination: ITAT Amritsar

March 24, 2026 246 Views 0 comment Print

The tribunal held that taxing entire gross receipts is unsustainable and only profit embedded in receipts should be taxed. However, the matter was remanded as fresh evidence was admitted without giving the AO an opportunity to verify.

ITAT Mumbai Deletes LTCG Addition as No Evidence of Share Transaction Being Bogus

March 24, 2026 390 Views 0 comment Print

The case involved addition of share sale proceeds treated as bogus based on investigation reports. The Tribunal held that no direct evidence linked the assessee to manipulation. It ruled that documented transactions through banking and demat channels cannot be disregarded without proof.

ITAT Delhi Quashes Reassessment as Wrong Explanation Invoked & Casual Approval

March 24, 2026 339 Views 0 comment Print

The tribunal held that reopening of assessment was invalid due to invocation of the wrong Explanation under Section 147 despite a completed assessment under Section 143(3).

Delay in Filing Appeal Should Be Liberally Condoned When Sufficient Cause Exists – ITAT Bangalore

March 24, 2026 264 Views 0 comment Print

The issue was whether delay in filing appeal without strong documentary proof should be condoned. The ITAT held that when sufficient cause exists, delay must be liberally condoned to ensure justice and hearing on merits.

ITAT Kolkata Reduces Profit Estimation to 4% Due to Lack of Comparable Basis

March 23, 2026 798 Views 0 comment Print

The issue involved arbitrary estimation of income at 20% and 5% of turnover. The Tribunal reduced it to 4% due to lack of supporting comparables and considering business realities. The key takeaway is that estimation must be reasonable and justified.

ITAT Mumbai: AO Cannot Apply 50% Presumptive Rate U/s 44ADA to Business Income Declared U/s 44AD – Addition Deleted

March 23, 2026 834 Views 0 comment Print

The Tribunal ruled that section 44ADA applies only to specified professions and cannot be invoked for business income covered under section 44AD. Arbitrary substitution of a higher rate by the AO was held unsustainable.

ITAT Visakhapatnam Quashes Reassessment as Section 148 Notice Time-Barred

March 21, 2026 405 Views 0 comment Print

The Tribunal held that a notice issued under section 148 beyond the six-year limitation under the old law is invalid. It clarified that the first proviso to section 149 bars such reopening even under the amended regime.

ITAT Mumbai deletes ₹21.99L Sec 69B addition; third-party statement without cross-examination held invalid

March 21, 2026 549 Views 0 comment Print

The case involved addition for alleged on-money payment based on search findings of a builder. The ITAT ruled that absence of corroborative evidence and denial of cross-examination makes the addition unsustainable.

Addition Based on Third-Party Software Data Invalid Without Cross-Examination: ITAT Mumbai

March 21, 2026 888 Views 0 comment Print

The Tribunal held that the addition based on third-party software data was invalid as the material was not provided to the assessee. Denial of cross-examination was found to violate principles of natural justice.

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