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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 3495 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1647 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 900 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2490 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 141 Views 0 comment Print

Retrospective Amendment Doesn’t Justify Reassessment Beyond Four Years

Income Tax : Bombay High Court sets aside IT reassessment against Oxford University Press, ruling no failure to disclose material facts for reo...

March 8, 2025 90 Views 0 comment Print

No valid assessment or reassessment can be made in name of deceased: ITAT Mumbai

Income Tax : ITAT Mumbai held that once the assessee is dead no valid assessment or reassessment can be made in the name of the deceased. Thus,...

March 7, 2025 315 Views 0 comment Print

Issue of reopening notice u/s. 148 by ACIT-Jaipur illegal as jurisdiction lies with ITO-Delhi

Income Tax : ITAT Jaipur held that issuance of notice under section 148 of the Income Tax Act by ACIT, Jaipur, is illegal and liable to be quas...

March 6, 2025 150 Views 0 comment Print

Reopening of assessment based on borrowed satisfaction not sustainable: Gujarat HC

Income Tax : Gujarat High Court held that reopening of assessment based on borrowed satisfaction without there being any link between informati...

March 6, 2025 87 Views 0 comment Print


Latest Notifications


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 246 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 9243 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 4068 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 5511 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 3021 Views 0 comment Print


AO Cannot Reassess Other Income Without Assessing Initial Grounds: Calcutta HC

March 6, 2025 477 Views 0 comment Print

Calcutta HC dismisses IT department’s appeal in CIT vs. Infinity Infotech, ruling reassessment cannot expand beyond recorded reasons under Section 147.

Reopening u/s. 147 based on communication without independent application of mind is invalid

March 5, 2025 153 Views 0 comment Print

Delhi High Court held that reopening of an assessment under section 147 of the Income Tax Act merely on the basis of communication from ACIT, without independent application of mind, is invalid and liable to be set aside.

Dismissal of appeal merely on account of non-prosecution not justified: ITAT Raipur

March 5, 2025 114 Views 0 comment Print

ITAT Raipur held that dismissal of appeal by CIT(A) without disposing off on merits, merely on account of non-prosecution is unjustifiable. Accordingly, order set-aside with direction to dispose off on merits.

Addition u/s. 69A not sustainable as nature and source of cash deposits duly explained

March 5, 2025 417 Views 0 comment Print

ITAT Chennai held that addition under section 69A of the Income Tax Act towards unexplained money not legally sustainable since nature and source of cash deposits duly explained. Accordingly, addition is liable to be deleted.

Delay in issuing Section 143(2) Notice Renders Reassessment Invalid: Delhi HC

March 5, 2025 2025 Views 0 comment Print

The Delhi High Court quashed a tax reassessment notice issued to Indus Towers Ltd. for AY 2009-10, citing procedural lapses and missed statutory deadlines.

JAO can issue Section 148 notice after Section 132 search: Gujarat HC

March 4, 2025 1293 Views 0 comment Print

Gujarat High Court rules that a jurisdictional assessing officer cannot override the faceless assessment scheme under Section 151A of the Income Tax Act.

100% Disallowance of Bogus Purchases Mandated when source not explained: Bombay HC

March 4, 2025 5181 Views 0 comment Print

Bombay High Court upholds AO’s addition for unverified bogus purchases in PCIT vs. Kanak Impex. Decision based on Section 69C and apex court precedents.

ITAT Delhi quashing Levy of penalty u/s 271(1) beyond period of limitation

March 4, 2025 1521 Views 0 comment Print

ITAT Delhi quashes penalty on Babu Ram u/s 271(1)(c) as barred by limitation. Penalty order dated April 1, 2022, violated extended timelines due to COVID-19.

Addition u/s. 69 without any concrete evidence against assessee is not sustainable

March 4, 2025 186 Views 0 comment Print

ITAT Mumbai held that addition under section 69 towards unexplained cash made by the AO without bringing any concrete evidence on record incriminating the assessee is not sustainable. Accordingly, addition u/s. 69 deleted.

Sundry Debtors Not Unexplained Money Under Section 69A: ITAT Jaipur

March 3, 2025 930 Views 0 comment Print

ITAT Jaipur held that amount of sundry debtor recorded in books of account are not any money, bullion, jewellery or other valuable article and hence doesn’t qualify as unexplained money under section 69A of the Income Tax Act.

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