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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


Appeal Can’t Be Dismissed Mechanically u/s 249(4)(b) – ITAT Grants Assessee Fresh Opportunity

September 17, 2025 261 Views 0 comment Print

The ITAT Kolkata bench restored an appeal, ruling that an appeal cannot be mechanically dismissed under Section 249(4)(b) and that natural justice demands a fair hearing.

Non-Speaking Ex Parte Order Quashed – ITAT Rajkot Sends Back Case with Costs

September 17, 2025 207 Views 0 comment Print

The ITAT Rajkot set aside a CIT(A) order against Prataprai Ranpariya, ruling that the ex-parte dismissal violated principles of natural justice. The Tribunal remanded the matter for a fresh hearing, imposing a Rs.2,000 cost on the assessee for non-compliance.

Revision proceedings u/s. 263 set aside as AO already made proper enquiry and examination

September 16, 2025 669 Views 0 comment Print

ITAT Delhi held that revisionary proceedings under section 263 of the Income Tax Act is not justifiable since proper enquiry and examination was made and therefore, there is no error in the order of the AO thus, it is not pre-judicial to the interest of the Revenue.

ITAT Kolkata Deletes ₹1.59 Crore Bogus Sales/Paper Trading Addition

September 15, 2025 894 Views 0 comment Print

The ITAT Kolkata dismisses the Revenue’s appeal, ruling that a ₹1.59 crore addition for alleged bogus sales was unfounded, as the company provided substantial evidence including e-way bills and bank statements.

ITAT Pune Quashes Reassessment u/s 147, Says Search Cases Must Proceed u/s 153C

September 15, 2025 786 Views 0 comment Print

The Pune ITAT quashed a reassessment order, ruling that proceedings initiated under Section 147 were invalid. The tribunal held that information from a third-party search mandates proceedings under Section 153C, not Section 147.

Order of Income Tax assessment without issuing DIN was void ab initio

September 15, 2025 1422 Views 0 comment Print

AO was bound to follow the CBDT circular 19/2019 (F. NO.225/95/2019-ITA.II], DATED 14-8­2019 and the omission/dereliction was anathema to the basic feature of our Constitution “Rule of Law”, so his impugned action of passing the assessment order without quoting the DIN was held to be arbitrary exercise of power and therefore, invalid.

Mechanical “Approved” Sanction Void – ₹8.11 Cr Additions Deleted by ITAT Delhi

September 15, 2025 747 Views 0 comment Print

ITAT Delhi quashes ₹8.11 Cr addition, ruling reassessment void due to mechanical approval by JCIT. AO’s lack of independent mind also cited. Safeguards are not rituals.

ITAT Delhi Quashes Assessments Due to Invalid Section 153D Approval

September 14, 2025 1221 Views 0 comment Print

ITAT Delhi quashes assessments under Section 153A due to “mechanical” Section 153D approval by the Additional CIT. The tribunal emphasized that this approval is a mandatory safeguard, not a mere formality, and its lack of application of mind renders assessments void.

AO’s Plausible View Cannot Be Replaced by PCIT’s Suspicion – ITAT Quashes Revision

September 13, 2025 411 Views 0 comment Print

The ITAT Jaipur has quashed a PCIT’s revision order, holding that a Principal Commissioner cannot override an Assessing Officer’s plausible view with a mere suspicion.

Substance Over Suspicion – Borrowed Satisfaction on Client Code Modification Not Valid –  ITAT Jaipur Quashes 147  

September 13, 2025 444 Views 0 comment Print

The ITAT Jaipur invalidates a reassessment order against Anusha Finvest Pvt. Ltd., ruling that reopening on “borrowed satisfaction” without independent inquiry is illegal.

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