Sponsored
    Follow Us:

Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 6009 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1668 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 924 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2502 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


Addition u/s. 68 restricted to 0.30% of total Circular Trading Transaction: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that CIT(A) rightly restricted disallowance on account of unexplained bank deposit and withdrawal under sectio...

March 10, 2025 63 Views 0 comment Print

Reassessment not Change of Opinion if original assessment not involve any formation of opinion

Income Tax : It was held that in the original assessment under Section 143(1), the issue related to the deed of purchase of land was not looked...

March 10, 2025 42 Views 0 comment Print

Reassessment notice issued u/s. 148 beyond six years is time barred: ITAT Mumbai

Income Tax : ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. A...

March 10, 2025 663 Views 0 comment Print

ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...

March 9, 2025 156 Views 0 comment Print

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....

March 9, 2025 264 Views 0 comment Print


Latest Notifications


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 246 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 9252 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 4101 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 5511 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 3021 Views 0 comment Print


Re-Assessment Invalid if order sheet recording reason for reopening is unsigned

February 28, 2018 2202 Views 0 comment Print

Sri Pinnamaraju Venkatapathi Raju Visakhapatnam Vs JCIT (ITAT Visakhapatnam) In the instant case, on verification of the assessment record, it is noticed that the A.O. typed the reasons but not signed the order sheet, thus there are no reasons recorded for reopening of assessment as required u/s 148 of the Act. The A.O. neither complied […]

Unsigned reason cannot be treated as reasons recorded

February 28, 2018 1785 Views 0 comment Print

Where AO typed the reasons but not signed the order sheet, there were no reasons recorded for re-opening assessment as required under section 148, therefore, notice issued under section 148 was bad in law, consequently reassessment order was to be annulled.

Section 148 notice without proper sanction U/s. 151(1) is invalid

February 27, 2018 5178 Views 0 comment Print

The present petition under Article 226 of the Constitution of India has been filed assailing the notice dated 28.03.2017 issued under Section 148 of the Income Tax Act, 1961 (in short, the Act) and also the order dated 25.09.2017 whereby the objections preferred by the petitioner questioning the issuance of notice dated 28.03.2017 was rejected.

Notice U/s. 148 invalid if AO not issued notice U/s. 143(2)

February 21, 2018 8745 Views 0 comment Print

Pr. CIT Vs. Paramount Biotech Industries Ltd. (Delhi High Court) The proposal to reopen an assessment under section 147 of the Act is to be based on reasons to be recorded by the assessing officer. Such reasons have to be communicated to the assessee. However, merely because the assessee participates in the proceedings pursuant to […]

HC finds no merit in Challenge to Reassessment Notice issued to Robert Vadra’s Firm

February 20, 2018 1938 Views 0 comment Print

Delhi High Court has refuses to set aside re-assessment notice U/s. 147/148 issued by Income Tax Department to the partnership firm Sky Light Hospitality, in which Robert Vadra is a partner, in connection with the DLF- Sky Light Hospitality land deal.

Mere Issue of 2nd notice U/s. 148 does not constitute Change of Opinion; AO can examine genuineness of share premium U/s 68

February 9, 2018 1263 Views 0 comment Print

The assessee, a company stated to be engaged in Real Estate business, filed its return of income for Assessment Year 2008-09 on 30.09.2008 declaring loss of (-) Rs.6,84,051. The assessee filed a revised return on 14.10.2008 declaring loss of (-) Rs.5,23,751. The revised return was processed under Section 143(1) of the Income Tax Act

Sec 292B can’t be cure Non-application of mind in issue of Re-Assessment Notice

February 7, 2018 1788 Views 0 comment Print

Smt. Kalpana Shantilal Haria Vs. Assistant CIT (Bombay High Court) There can be no dispute with regard to the application of Section 292B of the Act to sustain a notice from being declared invalid merely on the ground of mistake in the notice. However, the issue here is not with regard to the mistake / […]

No reassessment merely for non reflection of ITR filed manually in IT system

February 7, 2018 3201 Views 0 comment Print

In ground No. 1 of the appeal, the assessee has challenged the initiation of proceedings u/s. 147 of the Act for deposition of cash of Rs. 1057000 in the saving bank account during the financial year 2006-07 based on AIR Information and not filing of return of income by the assessee.

Sanction for issuing a reopening notice cannot be mechanical

January 28, 2018 1539 Views 0 comment Print

It is a settled principle of law that sanction granted by the higher Authority for issuing of a reopening notice has to be on due application of mind. It cannot be an mechanical approval without examining the proposal sent by the Assessing Officer.

Penalty cannot be imposed for Bonafide omission during return filing, surfaced during Section 148/148 Assessment

January 25, 2018 3498 Views 0 comment Print

In the instant case, nothing is on record to show that there was any malafide intention on the part of the assessee to conceal the income or furnish inaccurate particulars of income and there was an omission while filing the return of income which was rectified through challan on the very date of passing the assessment order.

Sponsored
Sponsored
Search Post by Date
March 2025
M T W T F S S
 12
3456789
10111213141516
17181920212223
24252627282930
31