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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 87 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 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


Reassessment u/s. 148 on same ground already considered by AO cannot be sustained

September 24, 2025 489 Views 0 comment Print

Gujarat High Court held that the proceedings under Section 148 of the Income Tax Act cannot be initiated to review the earlier stand adopted by the Assessing Officer. Accordingly, initiation of reassessment proceedings u/s. 148A(d) on the same ground which is already considered by AO cannot be sustained.

ITAT Mumbai Restores Bogus Purchase Case – CIT(A) Erred by Denying AO Opportunity

September 24, 2025 219 Views 0 comment Print

Mumbai ITAT has restored a bogus purchases case to the Assessing Officer for a fresh hearing, ruling that CIT(A) erred by partially restricting the addition without giving the assessee a full opportunity to present evidence.

Income Tax Section 148A vs. Section 135A

September 24, 2025 2850 Views 0 comment Print

Learn about the changes to income tax reopening proceedings under the Finance Act, 2021. This summary explains the new Section 148A and its relationship with Section 135A, highlighting key procedural points and common issues.

Genuine Loan vs Alleged Accommodation Entry: Addition deleted, Reopening Valid

September 24, 2025 804 Views 0 comment Print

The ITAT Ahmedabad deleted a Rs.30.5 lakh addition, ruling the loan was genuine and supported by bank records, while upholding the reopening of the assessment.

Gujarat HC Quashes Income Tax reassessment for Ignoring Taxpayer Submissions

September 24, 2025 870 Views 0 comment Print

Gujarat HC set aside an income tax reassessment order after the AO failed to consider the taxpayer’s detailed reply, emphasizing adherence to natural justice principles.

ITAT Ahmedabad Condones Delay in Filing Appeals Due to Wrong Email Notices

September 24, 2025 375 Views 0 comment Print

Briya Enterprise Ltd. successfully had delays in filing appeals condoned after ITAT held that notices sent to outdated email IDs and old Authorized Representatives justified the delay. Appeals were restored to CIT(A) for fresh decisions on merits.

Karnataka HC Quashes Non-Faceless Section 148A Reassessment Notices by Jurisdictional AO

September 24, 2025 1947 Views 0 comment Print

Ramachandra Reddy Vs DCIT: The Karnataka High Court quashes reassessment notices issued by jurisdictional AOs, holding that after the March 29, 2022 notification, all such proceedings must be conducted via the mandatory faceless regime under Section 151A.

Reassessment notice u/s. 148 without DIN is invalid and non-est

September 23, 2025 1197 Views 0 comment Print

ITAT Chennai held that reassessment notice under section 148 of the Income Tax Act without mandatory Document Identification Number [DIN] is invalid, non-est and hence liable to be quashed. Accordingly, assessment order thereon also collapses.

Time-Barred Reassessment Notices Quashed: Limitation Period Enforced

September 23, 2025 1284 Views 0 comment Print

ITAT Delhi ruled that reassessment notices issued in July 2022 for AYs 2015-16 and 2016-17 were barred by limitation, citing a Supreme Court precedent.

Reassessment on Illiquid Derivatives Set Aside as notice was time-barred

September 23, 2025 633 Views 0 comment Print

The ITAT Mumbai ruled in favor of Nilesh Shirish Mehta, setting aside a reassessment order for AY 2015-16. The tribunal found the Section 148 notice, issued after April 1, 2021, to be time-barred and invalid based on concessions made by the Department before the Supreme Court in the case of Union of India v. Rajeev Bansal.

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