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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


Bombay High Court Quashes Reassessment for Invalid Service and Approval

November 1, 2025 3246 Views 0 comment Print

The Court held that reassessment proceedings under Sections 148A and 148 were void as notices were not validly served and proper approval from PCCIT was not obtained.

Reassessment Quashed for Lack of Proper Sanction Under Section 151

November 1, 2025 1083 Views 0 comment Print

Bombay High Court set aside reassessment proceedings for AY 2016–17 as the sanction was granted by an unauthorized officer, holding that approval must come from senior authorities under Section 151(ii).

One-Day Delay Can’t Deny Justice – ITAT Rajkot Restores NRI’s Case to DRP

October 31, 2025 708 Views 0 comment Print

ITAT Rajkot held that a one-day delay in filing objections before the DRP should not defeat justice. The Tribunal condoned the delay and remanded the case for fresh adjudication, emphasizing that natural justice must prevail over technical lapses.

Failure to Follow Rule 46A Procedure Leads to Remand: Tribunal Allows Appeal for Statistical Purposes

October 31, 2025 609 Views 0 comment Print

The Delhi ITAT restored a reassessment appeal to the CIT(A) because evidence was rejected only for lack of a formal Rule 46A application. The Tribunal directed the CIT(A) to admit the additional evidence if the assessee files a proper application within a reasonable time.

Notice u/s 148 Issued Beyond ‘Surviving Time’ Quashed: ITAT Follows Rajeev Bansal (SC)

October 31, 2025 918 Views 0 comment Print

An assessment adding ₹17.62 lakh was annulled as the income was below ₹50 lakh, limiting the period to three years under Section 149(1)(a). The Tribunal held the notice was time-barred as it was reissued after the statutory period’s surviving time of one day expired.

Electronic Upload on ITBA = Legal Receipt: Physical Delivery Irrelevant, Says Delhi HC

October 31, 2025 804 Views 0 comment Print

Delhi HC ruled that date of electronic upload of DRP directions on ITBA is date of receipt under Section 144C(13). AO’s final order passed a day late was held invalid, reaffirming that physical delivery is irrelevant once uploaded.

Mass Rubber-Stamp Approval Under Section 153D Invalid: Delhi HC:

October 31, 2025 420 Views 0 comment Print

The Delhi High Court dismissed the Revenue’s appeal, affirming that a prior approval for search assessments under Section 153D must involve the superior authority’s conscious application of mind. The Court held that approvals granted mechanically or through a single omnibus letter for numerous assessments are invalid, thereby quashing the assessment.

Mechanical Approval & Loose Papers Can’t Justify Additions – ITAT Delhi Deletes All Additions

October 31, 2025 321 Views 0 comment Print

The ITAT struck down the additions, observing that the AO’s jurisdiction was potentially vitiated by a mechanical, consolidated approval for reopening, and the additions themselves relied solely on an uncorroborated statement and rough papers. The ruling confirms that unverified, rough documents lack sufficient evidentiary value to sustain income additions.

Reassessment Based on Change of Opinion Invalid – ITAT Delhi Quashes Section 147 Action  

October 31, 2025 948 Views 0 comment Print

The ITAT Delhi ruled that the reassessment was invalid because the issue of setting off prior-year speculative losses was already examined in the original scrutiny assessment. The quashing relied on the “change of opinion” doctrine, as the AO used no new tangible material to reopen the case.

Reassessment Quashed for Invalid Approval Beyond 4 Years from PCIT

October 31, 2025 1704 Views 0 comment Print

ITAT Delhi held that reopening beyond four years requires sanction from the Principal Commissioner or Commissioner. Approval taken from the Joint Commissioner rendered the reassessment invalid.

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