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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


Reassessment proceedings based on incorrect information liable to be quashed

April 29, 2025 2217 Views 0 comment Print

Patna High Court held that reassessment proceedings initiated on the basis of incorrect information which was not supported by any material is not sustainable in law. Accordingly, order passed thereon is liable to be quashed.

Assessments Can Be Reopened on Credible Escaped Income Information: Rajasthan HC

April 29, 2025 1527 Views 0 comment Print

Rajasthan High Court backs tax authorities’ power to reopen assessments based on new information, citing Supreme Court rulings on ‘reason to believe’.

ITAT Kolkata Quashes Reassessment, Invalidates Mechanical Sanction After 4 Years

April 27, 2025 2361 Views 0 comment Print

Kolkata ITAT cancels reassessment, rules CIT’s mechanical sanction for reopening after 4 years invalid; upholds assessee’s challenge based on lack of recorded satisfaction.

Providing less than 7 days to reply is against mandate of Section 148A(b): ITAT Raipur

April 26, 2025 1896 Views 1 comment Print

ITAT Raipur held that providing unreasonably short period of time of six days for furnishing reply vide notice issued u/s. 148A(b) of the Income Tax Act is against the mandate of law and hence liable to be set aside.

Income Tax Writ disposed due to existence of alternative remedy: Madras HC

April 24, 2025 585 Views 0 comment Print

Madras High Court held that the existence of an alternative remedy precludes the petitioner from approaching this Court through a writ petition unless there is an exceptional circumstance.

Calcutta HC granted liberty to respond to notice issued u/s. 148

April 24, 2025 753 Views 0 comment Print

Calcutta High Court held that liberty is granted to the petitioner to respond to notice issued under section 148 of the Income Tax Act as the respondents are on the verge of bringing the assessment proceedings to a conclusion.

ITAT Ahmedabad quashes Ex-Parte Order for Ignoring Objections to Mechanical Reopening

April 23, 2025 1185 Views 0 comment Print

Tribunal also took note of the fact that AO had merely reproduced identical reasons for multiple years without verifying facts or forming a belief based on individual year-specific material.

Assessment Order Violates Natural Justice Due to SOP u/s 144B Breach: Bombay HC

April 23, 2025 2298 Views 0 comment Print

Bombay High Court held that department have acted contrary to the SOP under section 144B of the Income Tax Act violating the principles of natural justice. Accordingly, assessment order passed thereon is liable to be quashed.

Section 148 Reopening based on incorrect facts & reasons is invalid: ITAT Delhi

April 23, 2025 2871 Views 0 comment Print

ITAT Delhi held that reopening of assessment under section 148 of the Income Tax Act based on incorrect facts and incorrect recording of reasons is invalid and bad-in-law. Accordingly, reopening is liable to be quashed.

Section 115JB not applicable to banking companies: ITAT Bangalore

April 23, 2025 654 Views 0 comment Print

ITAT Bangalore exempts Canara Bank from MAT, citing Delhi HC rulings on non-applicability of Section 115JB to banking companies before 2012 amendment.

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