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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


Madras HC Sets Aside Reopening Beyond 4 Years Based on Disclosed Facts

July 29, 2025 927 Views 0 comment Print

Madras High Court ruled that income tax reassessment based on information already available in audited financial statements is invalid, finding no failure by the company to disclose material facts.

ITAT Accepts Delay of 234 days Due to Accountant Exit, Restores Appeal

July 29, 2025 387 Views 0 comment Print

ITAT Ahmedabad condones a 234-day delay in an income tax appeal, citing missed email communication due to an accountant’s resignation, remanding the case for re-adjudication.

LTCG Claim in NYSSA Stock Is Bogus, Calcutta HC Upholds ₹9.16 Lakh Addition

July 26, 2025 1068 Views 0 comment Print

Calcutta High Court restores reassessment for bogus LTCG, finding ITAT erred by ignoring AO’s evidence and satisfaction in a penny stock scam, citing Supreme Court precedents.

Disallowance should be restricted to profit element in case of of bogus purchases when sales were not doubted

July 25, 2025 573 Views 0 comment Print

When sales were not doubted, entire purchases could not be disallowed merely on the ground that suppliers were non-genuine, it was deemed appropriate to restore the matter back to the file of AO for carrying out limited verification and addition should be restricted to profit estimation.

Notices issued without compliance with Non-Faceless assessment procedure was invalid

July 25, 2025 1143 Views 0 comment Print

Notices issued to a taxpayer on the ground that the Income Tax Department failed to issue them in compliance with the mandatory faceless assessment procedure, thus disregarding binding judicial precedents that have adjudicated on the matter was invalid.

Income Tax Appeal Before Wrong Forum; HC Allows Correction & Stays Recovery for a Month

July 24, 2025 399 Views 0 comment Print

The Kerala High Court has stayed recovery proceedings for one month, allowing petitioners to shift their income tax appeals to the Tribunal under Section 253(1)(d).

Receipt of payment cannot be qualified as FTS merely because service require technical expertise

July 24, 2025 747 Views 0 comment Print

Delhi High Court held that payments received for services that may require technical expertise, technical inventions or technology would not qualify as Fees for Technical Services under Article 13 of the India-UK DTAA. Accordingly, appeal allowed.

Addition merely on basis of available information without independent investigation is unsustainable

July 24, 2025 2064 Views 0 comment Print

ITAT Delhi held that addition towards earning fictitious profit by misusing Client Code Modification Facility merely on the basis of information received from Investigation wing without carrying out independent investigation is unsustainable in law. Accordingly, appeal of revenue dismissed.

Reassessment u/s. 148 based on suspicion without cogent material is bad-in-law

July 24, 2025 675 Views 0 comment Print

ITAT Delhi held that initiated the reassessment proceedings under section 148 of the Income Tax Act only on the basis of suspicion of involvement in money laundering activity without cogent material brought is bad-in-law. Accordingly, appeal allowed.

Reassessment was valid where audit objections could qualify as “Information” u/s 148A

July 23, 2025 1155 Views 0 comment Print

Reassessment proceedings could not be sustained in respect of other issues raised in the audit except in respect of two specific expenditure heads: processing charges and professional fees as the same could be treated as “information” under Section 148A.

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