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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 Condoned Delay, Restores ₹4.63 Cr Cash Deposit Case for Fresh Hearing

September 4, 2025 348 Views 0 comment Print

ITAT Bangalore sets aside tax demand of ₹7.29 crore on a rural co-op society, citing its inability to explain a ₹4.63 crore cash deposit due to a negligent tax practitioner.

Calcutta HC Quashes IT Notice for AY 2019-20 Over Lack of Personal Hearing

September 4, 2025 363 Views 0 comment Print

Calcutta High Court overturns Usha Martin Telematics tax order for 2019-20, citing a violation of natural justice after a personal hearing was denied.

Limitation Period u/s 153C commenced from date of receipt of seized material by AO and not from date of search or notice

September 4, 2025 1104 Views 0 comment Print

Under Section 153C, the six-year limitation period for issuing a notice to a person other than the one searched begins from the date on which the documents or materials were received by AO, not from the date of the search or notice.

No reassessment if limitation period barred u/s 153(2) unless TPO reference u/s 92CA was involved in case of non-residents

September 4, 2025 741 Views 0 comment Print

Revenue argued that since assessee was an “eligible assessee” under section 144C(15), AO rightly passed the order and the final order was valid within the time limit of section 153(4). On appeal.

No addition u/s 68 and 69C for Penny Stock case without any evidence

September 4, 2025 831 Views 0 comment Print

Mere involvement in a flagged scrip, in absence of concrete evidence of manipulation or unaccounted funds, could not justify taxing bonafide transactions. Therefore, the additions under sections 68 and 69C were unsustainable.

No Proof of Accommodation Entries, ₹3.62 Cr Addition Unsustainable

September 4, 2025 909 Views 0 comment Print

Tribunal confirmed CIT(A)’s view that alleged accommodation loans were not supported by bank statements. Reopening and addition u/s 69A struck down; Revenue’s case dismissed.

Amount gifted by brother cannot be treated as unexplained: ITAT Chennai

September 2, 2025 231 Views 0 comment Print

ITAT Chennai held that the amount gifted by the brother cannot be treated as unexplained. Accordingly, addition u/s. 69 of the Income Tax Act deleted to that extent. In the result, the appeal is partly allowed.

ITAT Mumbai capped Bogus Purchases Addition at 12.5% Gross Profit

September 1, 2025 690 Views 0 comment Print

The ITAT Mumbai has upheld a decision to restrict a bogus purchase addition to a 12.5% gross profit rate, citing a Bombay High Court precedent, in the case of DCIT vs. S. Rasiklal and Co.

ITAT Sets Aside Penalty Order as core quantum appeal was pending

September 1, 2025 987 Views 0 comment Print

The ITAT has set aside a penalty order against a taxpayer, Murmu Pankaj Kumar, ruling it was premature as the core quantum appeal was still pending before the CIT(A).

ITAT Delhi quashes assessment on Company under Liquidation – IBC moratorium overrides Income Tax Proceedings

September 1, 2025 780 Views 0 comment Print

ITAT Delhi: Assessment against a company in liquidation is quashed. The IBC moratori-um overrides the Income Tax Act, rendering the tax proceedings null and void.

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