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Section 147

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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 390 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 576 Views 0 comment Print

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 729 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 1032 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 3180 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 2277 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 4389 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 7494 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 13344 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 42813 Views 2 comments Print


Latest Judiciary


Reversal of Previously Disallowed Securitisation Provisions Cannot Be Taxed Again: ITAT Mumbai

Income Tax : The Mumbai ITAT held that reversal of securitisation provisions already disallowed in earlier years cannot be taxed again upon wri...

May 21, 2026 78 Views 0 comment Print

ITAT Mumbai Quashes Reassessment as Section 148 Notice Was Issued Beyond Surviving Limitation Period

Income Tax : ITAT Mumbai held that the reassessment notice issued on 24.07.2022 was time-barred under the Supreme Court ruling in Rajeev Bansal...

May 20, 2026 102 Views 0 comment Print

ITAT Delhi Quashes Reassessment as Reopening Was Based Only on Audit Objection

Income Tax : The Delhi ITAT held that reassessment proceedings initiated solely on the basis of a revenue audit objection without fresh tangibl...

May 20, 2026 81 Views 0 comment Print

Reassessment Quashed as AO Used Section 147 Instead of Mandatory Section 153C

Income Tax : ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 15...

May 20, 2026 162 Views 0 comment Print

Section 263 Proceedings Quashed as AO’s Order Was Not Erroneous in Jewellery Case

Income Tax : The Tribunal held that the reassessment order could not be revised under Section 263 since the conditions for treating jewellery e...

May 20, 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 5817 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 846 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 10305 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 5892 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 5907 Views 0 comment Print


Reopening Valid Where Income Escapement Based on Search-Derived Information

April 21, 2026 411 Views 0 comment Print

The Tribunal confirmed addition of unexplained investments where the assessee could not substantiate the source of deposits. The ruling reinforces the burden of proof on the taxpayer.

Income Tax Refund Cannot be Adjusted When Recovery Is Stayed: Orissa HC

April 21, 2026 462 Views 0 comment Print

The Court held that adjusting a refund against a disputed demand during the subsistence of a stay order is illegal and arbitrary, directing release of the refund with interest.

ITAT Remands Case Due to Lack of Opportunity to Substantiate Bogus Expense Claim

April 21, 2026 2820 Views 0 comment Print

The Tribunal set aside the appellate order as the assessee sought another chance to prove the genuineness of expenses. It directed fresh assessment after proper opportunity of hearing.

Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

April 21, 2026 729 Views 0 comment Print

ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid. The burden of proof lies on the department.

ITAT Remands ₹1.57 Cr Addition as NRE Deposit Evidence Not Properly Examined

April 20, 2026 345 Views 0 comment Print

The case involved additions for unexplained bank deposits where the assessee later produced authenticated NRE account evidence. ITAT remanded the matter, directing fresh consideration of documents and proper opportunity of hearing.

Petition dismissed observing that Court cannot act as an AO and call documents which can be done by AO

April 20, 2026 336 Views 0 comment Print

Delhi High Court held that challenge to reassessment proceedings initiated under Income Tax Act failed as Court cannot act as an AO and call such documents which otherwise can be done by AO. Accordingly, petition dismissed.

Interest on deposits linked to business setup was capital receipt and not taxable as ‘Income From Other Sources’

April 20, 2026 648 Views 0 comment Print

Interest earned on funds kept in bank during business setup, when those funds were directly linked to the project, was a capital receipt and not taxable as “income from other sources

No Penalty When Quantum Deleted: 270A Cannot Survive Without Addition

April 18, 2026 444 Views 0 comment Print

ITAT Mumbai deletes penalty under Section 270A as quantum addition was fully removed. Held that no under-reporting exists when assessed income equals returned income and TDS details are already on record.

Bogus Purchase Addition Limited to Profit Element Due to Accepted Sales: ITAT Mumbai

April 18, 2026 870 Views 0 comment Print

ITAT held that where sales are not disputed, entire purchases cannot be disallowed. Only 15% profit element was taxed, reinforcing that tax applies to real income, not gross receipts.

Notional Rent on Work-in-Progress Invalid – Section 23 Misapplied

April 18, 2026 162 Views 0 comment Print

The Tribunal held that unfinished properties classified as work-in-progress cannot be subjected to notional rent under section 23. Since construction was incomplete, the addition was deleted as legally unsustainable.

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