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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


Change of opinion cannot be basis for reassessment proceedings u/s. 148: Madras HC

July 19, 2025 678 Views 0 comment Print

Madras High Court held that reassessment proceedings under section 148 of the Income Tax Act initiated on the basis of change of opinion is invalid. Accordingly, appeal of revenue dismissed and substantial questions of law is answered in favour of assessee.

Reassessment notice issued by non-jurisdictional AO is bad-in-law

July 19, 2025 1455 Views 0 comment Print

ITAT Jaipur held that reassessment notice under section 148 of the Income Tax Act issued by the Assessing Officer [AO], having no jurisdiction, is invalid. Accordingly, assessment order and consequent proceeding are also invalid.

Income Tax Section 147/144B Order Appealable, Writ Not Maintainable: Calcutta HC

July 18, 2025 378 Views 0 comment Print

Calcutta High Court dismisses challenge against a Section 144B tax order, directing Ayashree Finvest to use available statutory appeal remedies despite accountant’s failure.

Interest to Partners Allowable Despite No Active Business: ITAT Cochin

July 18, 2025 465 Views 0 comment Print

 ITAT Cochin rules in favor of Muthoot Bankers, allowing deduction for interest paid to partners under Section 40B, overturning disallowance by lower authorities.

Reopening Quashed: AO Relied on Investigation Wing Without Applying Mind

July 17, 2025 993 Views 0 comment Print

Amritsar ITAT sets aside reassessment against Bhai Industries Pvt. Ltd., citing lack of independent AO application of mind and denial of cross-examination in bogus purchases case.

Reopening u/s 147 Invalid as AO Acted Solely on Investigation Wing’s Info: ITAT Amritsar

July 17, 2025 744 Views 0 comment Print

ITAT Amritsar overturns Holy Faith International’s reassessment, citing AO’s failure to independently apply mind on external info and denial of cross-examination.

Calcutta HC Quashes Income Tax Section 154 Order Against Deceased Person

July 17, 2025 681 Views 0 comment Print

Calcutta High Court sets aside an Income Tax Act Section 154 order for AY 2013-14, as it was issued against a deceased individual, allowing the daughter-in-law’s appeal.

Second Opinion of AO cannot be Ground for Section 263 invocation

July 17, 2025 381 Views 0 comment Print

Income Tax Appellate Tribunal sets aside PCIT’s revisionary order against Synwave Industries, ruling original assessment not erroneous.

Reassessment u/s. 148 quashed as initiated inspite of full and true material disclosure: Bombay HC

July 15, 2025 735 Views 0 comment Print

Therefore, the amount distributed by it to the Petitioner would not qualify as exempt dividend income under Section 10(34) of the Act. This to our mind would be merely a “change of opinion”.

LTCG addition in hands of firm set aside as property belonged to partner & not firm

July 14, 2025 2019 Views 0 comment Print

ITAT Nagpur held that addition on account of LTCG in the hands of firm not justified as property is belonged to the partner in his individual capacity and didn’t belonged to the firm. Accordingly, order of CIT(A) upheld and appeal of revenue dismissed.

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