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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


Section 148 Notice quashed for Being Issued Beyond Time Limit for Income Below ₹50 Lakhs

June 13, 2025 1740 Views 0 comment Print

Mumbai ITAT quashes reassessment for Sonali Dharmendra Mhatre, ruling it time-barred under Section 149(1)(b) as the escaped income was below the Rs. 50 lakh threshold.

Gujarat HC Quashes Income Tax Reopening for Lack of application of mind

June 12, 2025 477 Views 0 comment Print

Gujarat High Court sets aside notice for assessment reopening against Bharatkumar Nihalchand Shah, citing the tax officer’s lack of proper application of mind and year discrepancy.

Section 271(1)(c) Penalty notice invalid if basis not specified: Delhi HC

June 12, 2025 1233 Views 0 comment Print

Delhi HC ruled in Sahara India Life Insurance Co. case that Section 271(1)(c) penalty is invalid if notice fails to specify whether it pertains to income concealment or inaccurate particulars.

No Penalty u/s 273B for Cash Loan Repayment on Lender’s Request to curb Interest Escalation

June 11, 2025 1338 Views 0 comment Print

AO held that assessee had made repayment of the loan to M/s. Tata Finance Corporation in that financial year to the extent of Rs. 6,71,939 in cash against the loan taken for commercial vehicle.

SC Dismisses Revenue’s Appeal: Reopening Notice Invalid due to change of Opinion

June 11, 2025 1440 Views 0 comment Print

SC upheld Gujarat HC’s decision to quash reassessment notice issued by Income Tax Department, citing lack of new material & change of opinion

Gujarat HC Quashes Income Tax Reopening Notice for Change of Opinion

June 11, 2025 702 Views 0 comment Print

The Gujarat High Court invalidated a tax reopening notice against Hemanshu Ramniklal Shah, ruling it was based on a “change of opinion” rather than new material, after the original assessment was already scrutinized.

Addition u/s 153A for completed assessments couldn’t be made without incriminating material

June 10, 2025 972 Views 0 comment Print

Since the assessments were completed in the case of assesee and there was no incriminating material found during the search in the case of the assessee, the additions made under Section 153A were unsustainable.

ITAT Amritsar Deletes Rs. 4.72 Lakh Cash Deposit Addition for Senior Citizen

June 8, 2025 768 Views 0 comment Print

ITAT Amritsar removes Rs. 4.72 lakh income addition for senior citizen, citing accumulated cash for emergencies. Overturns CIT(A) decision on bank deposit.

Reassessment Notice Quashed: No Prime Facie Evidence of Non-Genuine Investment

June 5, 2025 588 Views 0 comment Print

Bombay High Court overturns income tax reassessment notice for NuPower Renewables, citing no new information and prior scrutiny of share capital.

Email Dispatch Date Treated as electronic Notice Issue Date: Delhi HC

June 5, 2025 1113 Views 0 comment Print

Delhi High Court held that where notice is sent electronically, the date of dispatch of e-mail is to be considered as date of issue of notice and date of digital signature is irrelevant. Accordingly, petition dismissed.

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