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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


Reopening of assessment quashed as based on change of opinion: Bombay HC

May 31, 2025 1542 Views 0 comment Print

Bombay High Court held that since issue already examined during the course of assessment proceedings, re-opening of assessment on same issue amounts to change of opinion. Thus, re-opening based on change of opinion is not sustainable.

Order passed without considering reply is liable to be quashed: Gujarat HC

May 31, 2025 1701 Views 0 comment Print

Gujarat High Court held that reassessment order passed under section 148 of the Income Tax Act is liable to be quashed and set aside due to non-consideration of the reply in the assessment order. Accordingly, order set aside and matter remanded back to AO.

AO should evaluate claim of exemption u/s. 54F made in compliance to notice u/s. 148

May 31, 2025 1206 Views 0 comment Print

ITAT Ahmedabad held that claim of exemption under section 54F vide return of income filed in compliance to notice u/s. 148 needs to be evaluated by AO. Accordingly, matter restored back to the file of J.A.O. for making necessary verification for exemption claim.

ITAT Quashes 148 Notice as Income Below ₹50 Lakhs

May 31, 2025 3330 Views 0 comment Print

Pune ITAT ruled against reassessment for Kalpana Kadam, quashing a Section 148 notice as her share of property investment was below the ₹50 lakh threshold.

Reopening quashed as information in notice is ambiguous and fails to establish live link with evidence

May 30, 2025 1143 Views 0 comment Print

Rational connection postulates that there must be a direct nexus or live link between the material coming to the notice of the Income Tax Officer and his view that there has been escapement of income of the assessee from assessment in the particular year.

Reassessment u/s. 148 untenable as mandatory requirement of 149(1)(b) not complied

May 26, 2025 2295 Views 0 comment Print

Karnataka High Court held that assumption of jurisdiction under section 147 of the Income Tax Act untenable since mandatory requirement of section 149(1)(b) of the Income Tax Act not complied. Accordingly, writ petition allowed and notice u/s. 148 quashed.

Reassessment proceedings u/s. 148 in absence of any new material not permissible: Bombay HC

May 26, 2025 1374 Views 0 comment Print

Bombay High Court held that reopening of the assessment would be permissible without there being any new or additional material available to the Assessing Office. Accordingly, reassessment notice is set aside and writ petition is allowed.

Reopening u/s. 148 beyond 4 years quashed as material facts fully & truly disclosed: ITAT Raipur

May 24, 2025 1119 Views 0 comment Print

ITAT Raipur held that reopening of proceedings under section 148 of the Income Tax Act beyond a period of 4 years without failure on the part of the assessee to disclose fully & truly all the material facts is liable to be annulled.

Reassessment order set aside as passed without disposal of objections: Karnataka HC

May 24, 2025 1230 Views 0 comment Print

Karnataka High Court held that reassessment order under section 148 of the Income Tax Act is bad-in-law since passed without following mandatory procedure of disposal of objections. Accordingly, order of reassessment set aside.

Section 50C addition without referring to Valuation Officer not sustainable: ITAT Ahmedabad

May 24, 2025 1122 Views 0 comment Print

ITAT Ahmedabad held that addition invoking provisions of section 50C(2) of the Income Tax Act without referring the valuation of the capital asset to the valuation officer is not justifiable. Accordingly, matter restored back to AO to refer the matter to valuation officer for determining Fair Market Value.

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