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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


Principles Governing Reopening of Assessment Under Section 147 – Gujarat HC

June 28, 2025 2106 Views 0 comment Print

Meghavi Minerals Pvt Vs ITO (Gujarat High Court) Gujarat High Court has upheld the Income Tax Officer’s (ITO) decision to reopen the assessment of Meghavi Minerals Pvt. Ltd. for the assessment year 2012-13. The court rejected the company’s challenge to the Section 148 notice of the Income Tax Act, 1961, which initiated reassessment proceedings based […]

GKN Driveshafts: SC Clarifies Reassessment Process

June 28, 2025 1506 Views 0 comment Print

Supreme Court outlines mandatory steps for income tax reassessment, requiring AO to provide reasons and dispose of objections before assessment.

Different floors to be construed as single residential unit for Section 54F deduction: ITAT Delhi

June 27, 2025 753 Views 0 comment Print

ITAT Delhi held that different floors of a property cannot be construed as independent residential unit and instead had to be construed only as a single residential unit for purpose of claiming deduction u/s. 54F. Accordingly, grounds raised by revenue dismissed.

Setting Best Judgment Assessment to AO by CIT(A) Without Addressing Jurisdiction Validity Unjustifiable

June 27, 2025 1170 Views 0 comment Print

ITAT Hyderabad held that it is not obligatory on the part of the CIT(A) to set aside all the best judgment assessment orders passed u/s 144 of the Income Tax Act to the file of the AO. CIT(A) is obligated to address the grievance of validity of jurisdiction assumed by AO for initiating reassessment proceeding.

Reassessment U/S 147 Quashed Due to Full & True Disclosure of Material Facts

June 27, 2025 573 Views 0 comment Print

PCIT (Central)-2 Vs K.R. Pulp And Papers Ltd (Delhi High Court) Delhi High Court held that reopening of assessment under section 147 of the Income Tax Act rightly quashed by CIT(A) and ITAT since there was full and true disclosure of all the material facts on the part of the assessee. Accordingly, appeal of revenue […]

Deduction Allowed for Loss on Sale of Pledged Shares to Satisfy Sister Concern’s Dues

June 27, 2025 528 Views 0 comment Print

Madras High Court held that pledging of shares for the enable sister concern to avail loan is certainly an activity undertaken in the course of business. Accordingly, sale of shares thereon to satisfy dues of defaulting sister company is entitled for deduction of business loss/ debt.

ITAT Directs Appellant to Submit Documents for Section 12A Registration

June 27, 2025 339 Views 0 comment Print

ITAT Pune directed appellant to prove genuineness of activities; details of donations received and file audited financial statements for getting approval for regular registration u/s.12A r.w.s.12AB of the Income Tax Act. Accordingly, matter remitted back.

Passing of rectification order u/s. 154 without opportunity of being heard is bad-in-law

June 27, 2025 996 Views 0 comment Print

ITAT Pune held that rectification order under section 154 of the Income Tax Act passed without providing an opportunity of being heard is bad-in-law and deserved to be set aside. Accordingly, appeal of assessee allowed.

Donation/Capitation Fee Payment Case: ITAT Deletes Addition Due to Lack of Evidence

June 27, 2025 495 Views 0 comment Print

Delhi ITAT deletes ₹24 lakh unexplained expenditure addition on Hitesh Rohilla, citing lack of direct evidence linking alleged capitation fee payment to the assessee.

ITAT Delhi Directs AO to Apply Peak Credit Theory for Cash Deposits

June 27, 2025 771 Views 0 comment Print

The ITAT Delhi has directed the NFAC to apply the peak credit theory and allow set-off against agricultural income for unexplained cash deposits in the reassessment of Shakti Singh.

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