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Section 147

Latest Articles


FAQs on Assessments under Income-tax Law

Income Tax : Learn how different types of income tax assessments are conducted under the Income-tax Act. The FAQs explain assessment procedures...

June 24, 2026 93717 Views 7 comments Print

FAQs on Maintenance of books of accounts under Income Tax Act, 1961

Income Tax : This guide explains who is required to maintain books of account under Section 44AA based on business, profession, turnover, and i...

June 23, 2026 6204 Views 0 comment Print

Assessments under Income-Tax Act, 1961

Income Tax : This guide explains the various assessments under the Income-tax Act, including summary assessment, scrutiny assessment, best judg...

June 17, 2026 434522 Views 13 comments Print

Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...

May 13, 2026 579 Views 0 comment Print

CIT(A) cannot enhance income on issues not examined by AO: ITAT Mumbai

Income Tax : The Tribunal held that CIT(A) cannot enhance income under Section 251 on matters not considered by the Assessing Officer during as...

May 10, 2026 732 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 2430 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 4533 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 7512 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 13380 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 42888 Views 2 comments Print


Latest Judiciary


ITAT Quashes Reassessment as Section 151 Approval Was Not Obtained from Competent Authority

Income Tax : ITAT Pune held that the reassessment proceedings were invalid because the notice under Section 148 was approved by the Principal C...

June 24, 2026 198 Views 0 comment Print

Section 80P Deduction Allowed on Interest Income Attributable to Credit Society’s Business

Income Tax : ITAT held that interest earned by a co-operative credit society from deposits with a co-operative bank remained attributable to it...

June 24, 2026 105 Views 0 comment Print

ITAT Quashes Reassessment as Section 151 Approval Was Granted by Wrong Authority

Income Tax : ITAT Pune held that reassessment proceedings were invalid because the approval under Section 151 was granted by the Principal Comm...

June 24, 2026 135 Views 0 comment Print

SC Remands Over 1000 Reassessment Appeals After Finance Act 2026 Changed Law

Income Tax : The Supreme Court set aside High Court judgments quashing reassessment notices after noting that the Finance Act, 2026 introduced ...

June 24, 2026 2937 Views 0 comment Print

ITAT Deletes Section 68 Addition as Sale Proceeds Were Realisation of Earlier Investment

Income Tax : The ITAT held that Section 68 could not be applied to sale proceeds received from investments already recorded in the books in an ...

June 24, 2026 93 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 5928 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 906 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 10392 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 5991 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 5961 Views 0 comment Print


Reopening Invalid If Section 148 Notice Issued Before Formal Sanction: ITAT Kolkata

November 4, 2025 756 Views 0 comment Print

ITAT quashed a reassessment, ruling that S 148 notice was invalid because it was issued before AO formally received mandatory sanction from PCIT under S 151. Relying on Supreme Court, Tribunal held that internal approval is insufficient; communication of sanction to AO is a jurisdictional prerequisite.

Mechanical Acceptance of Return: ITAT Upholds Section Revision in Liquor Trader’s Case

November 4, 2025 522 Views 0 comment Print

Tribunal observed that AO accepted returned income without any independent examination or inquiry. As major issues like estimation of profit in liquor trade and tax audit requirements were ignored, assessment was held erroneous. Pr. CIT’s revision under Section 263 was sustained.

Addition on Alleged Inflated Purchases Based Solely on Third-party Data Deleted

November 4, 2025 591 Views 0 comment Print

ITAT Delhi deleted a ₹31.35 lakh addition for alleged inflated purchases, ruling that an assessment cannot rest solely on third-party search data. The Tribunal emphasized that the Revenue failed to conduct any independent enquiry or provide corroborating evidence linking the assessee to the alleged cash transactions.

Bogus Sales Profit Addition Remanded: CIT(A) Failed to Pass Speaking Order

November 4, 2025 333 Views 0 comment Print

ITAT Delhi remanded the addition of 12.5% profit on alleged bogus sales because the CIT(A) sustained the amount (₹20.16 lakh) without providing adequate reasoning or opportunity to the assessee. The Tribunal directed the CIT(A) to pass a fresh, speaking order after considering all submissions.

Appeal Delay Condoned: Accountant’s Email Error Caused Non-Compliance

November 4, 2025 639 Views 0 comment Print

ITAT Delhi condoned a significant delay in filing appeals, ruling the cause was bona fide as the accountant’s linked email ID led to the non-receipt of assessment and penalty notices. The Tribunal set aside the ex-parte assessment and penalty, remanding the case for a fresh hearing on merits.

Reassessment Invalid for Change of Opinion on 54F Claim – ITAT Quashes ₹1.63 Cr LTCG Addition

November 4, 2025 336 Views 0 comment Print

Hyderabad ITAT found reassessment unsustainable where 54F exemption was already examined in earlier scrutiny. As no new evidence emerged, reassessment under Section 147 was declared void.

Reassessment Quashed as Section 148 Notice Issued Before Mandatory Approval

November 4, 2025 543 Views 0 comment Print

The ITAT Delhi invalidated reassessment proceedings because the Section 148 notice was issued two days prior to obtaining the mandatory statutory sanction under Section 151 from the Additional Commissioner. The Tribunal held that obtaining the requisite approval is a precondition for valid reopening, and issuing the notice before approval renders the entire action void ab initio.

On-Money Addition Reduced by 70% as Only Profit Element is Taxable: ITAT Rajkot

November 4, 2025 483 Views 0 comment Print

The ITAT Rajkot significantly reduced an addition made under Section 69, ruling that in cases of alleged “on-money” payments found during a search, only the embedded profit component is taxable. Following the Gujarat High Court precedent, the Tribunal restricted the unexplained investment addition of Rs.1.25 lakh to just 30% (Rs.37,500).

Addition on “peak purchase” was restricted to differential margin between declared and benchmark profit in Rice Trading Case

November 4, 2025 324 Views 0 comment Print

Addition to the differential margin between the Gross Profit (GP) declared by the assessee and the benchmark rate of 10% adopted as the industry average for rice trading was restricted affirming that a full disallowance of such purchases was not justified when the corresponding sales were accepted by the Revenue authorities.

Delay in filing appeal condoned as plausible and sufficient cause shown

November 4, 2025 663 Views 0 comment Print

ITAT Bangalore held that delay in filing of appeal due to non-registration on Income Tax portal and non-receipt of notices are plausible and sufficient cause show. Accordingly, delay condoned and appeal restored back for fresh consideration.

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