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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 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


Reopening u/s. 148 quashed as based on mechanical approval u/s. 151

August 15, 2025 792 Views 0 comment Print

ITAT Delhi held that approval granted under section 151 of the Income Tax Act in mechanical manner without application of mind hence reopening of assessment based on such mechanical order is liable to be quashed.

Reopening u/s. 148 based on wrong facts is not sustainable: ITAT Chandigarh

August 15, 2025 444 Views 0 comment Print

ITAT Chandigarh held that foundation of reopening of assessment under section 148 of the Income Tax Act based on wrong facts is not justifiable. Hence, reopening of assessment is liable to be quashed.

No reassessment unless there was new tangible evidence found against assessee

August 14, 2025 306 Views 0 comment Print

Since no new material or facts had come to light and the AO had already applied his mind during the original assessment, the reassessment proceedings were invalid in law  accordingly, Section 148 notice was quashed.

Order of special audit not sustained as procedure mandated u/s. 142(2A) and 142(2C) not followed

August 13, 2025 489 Views 0 comment Print

ITAT Delhi held that order of special audit held to be void ab-initio since due procedure as mandated under the provisions of Sec. 142(2A) and Sec. 142(2C) of the Income Tax Act has not been followed.

Revision u/s. 263 initiated by CIT based on AO’s recommendation is not maintainable

August 13, 2025 978 Views 0 comment Print

ITAT Bangalore held that initiation of revisionary proceedings under section 263 of the Income Tax Act by CIT based on the recommendation of the AO is not maintainable. Accordingly, revisionary order set aside and appeal allowed.

No addition of cash deposits of ₹ 17.16 Lakh u/s 69A as demonetization deposits were valid until 31.12.2016

August 12, 2025 822 Views 0 comment Print

Cash deposits made by assessee during the demonetization period were properly explained and recorded, therefore, addition made under section 69A of ₹17,16,000 and taxed under section 115BBE was not sustainable.

Reassessment Void for Approval from Incorrect Authority Beyond Three Years

August 12, 2025 1203 Views 0 comment Print

The ITAT Ahmedabad set aside a reassessment order for Dalpat Baraiya, ruling that approval from the wrong authority invalidated the entire proceeding.

Sufficient cause shown for not attending hearing before CIT(A): Matter restored back to CIT(A)

August 12, 2025 582 Views 0 comment Print

ITAT Raipur held that passing of CIT(A) order was ex-parte without hearing the assessee and there is sufficient cause shown by assessee in not attending hearings as per opportunities granted by CIT(A). Accordingly, matter remanded back to CIT(A).

ITAT Delhi quashes reassessment for quoting repealed section & granting mechanical Approval

August 12, 2025 588 Views 0 comment Print

The ITAT Delhi has quashed a reassessment order against Sumit Suneja, finding that the AO quoted a repealed section of law and received a mechanical, undated approval.

ITAT Hyderabad Quashes Reopening: No Second Bite on Gift Addition – Change of Opinion Not Allowed

August 11, 2025 348 Views 0 comment Print

ITAT Hyderabad rules against the re-taxing of a gift, stating that revisiting the same facts to make a new addition is an impermissible “change of opinion.”

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