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Section 147

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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 747 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 2352 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 18090 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 393 Views 0 comment Print

Vague Income Tax Department’s New E-Intimations: Information or Intimidation?

Income Tax : This explains why recent income disclosure intimations lack statutory support and create uncertainty. The key takeaway is that vag...

January 1, 2026 6279 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 2103 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 4218 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 7434 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 13311 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 42729 Views 2 comments Print


Latest Judiciary


Appeal Cannot Be Dismissed for Non-Payment of Advance Tax When No Taxable Income Exists

Income Tax : ITAT held that section 249(4) cannot be invoked where no taxable income arises in India. Appeals must be decided on merits rather ...

April 13, 2026 12 Views 0 comment Print

ITAT Mumbai: Second Reopening Based on Same Material Is Invalid-Change of Opinion Not Permissible

Income Tax : The Tribunal ruled that reassessment cannot be reopened on issues already examined earlier. It held that absence of fresh material...

April 13, 2026 33 Views 0 comment Print

ITAT Mumbai: Sec 54 Claim Cannot Be Denied Merely for No Original Return-Allowed in Reassessment

Income Tax : The Tribunal clarified that filing of original return is not mandatory for claiming exemption under Section 54. It directed verifi...

April 13, 2026 57 Views 0 comment Print

ITAT Mumbai: Reopening Invalid Without Proper Sanction-Approval by Wrong Authority Vitiates Entire Proceedings

Income Tax : ITAT Mumbai holds reassessment invalid where approval under Section 151 was obtained from incorrect authority, ruling defect as ju...

April 13, 2026 36 Views 0 comment Print

ITAT Mumbai: Reopening Beyond 3 Years Invalid Where Escaped Income & lt; ₹50L-Notice u/s 148 Quashed

Income Tax : ITAT Mumbai quashes reopening beyond 3 years where escaped income is below ₹50 lakh, holding notice under Section 148 time-barre...

April 13, 2026 45 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 5673 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 768 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 10224 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 5700 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 5844 Views 0 comment Print


Bombay HC Quashes Reassessment as Section 148 Notice Issued by Wrong Authority

February 19, 2026 864 Views 0 comment Print

The Court held that issuance of notice under Section 148 by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer is a jurisdictional defect. All consequential reassessment proceedings were set aside.

Mere Third-Party Excel Sheet Insufficient for Section 69 Addition: ITAT Chandigarh

February 19, 2026 5145 Views 0 comment Print

The alleged unexplained investment was based only on third-party statements and seized digital data. In absence of receipts, confirmations, or admission by the assessee, the addition of ₹50 lakh was deleted.

ITAT Guwahati Quashes Reassessment Notice, Treats Loose Sheets as Dumb Documents, Deletes Protective Sec 69C Addition

February 19, 2026 654 Views 0 comment Print

ITAT dismissed the Revenues appeal because it did not contest the CIT(A)s ruling that the reassessment notice was legally invalid. Without challenging the jurisdictional defect, the appeal became infructuous.

ITAT Hyderabad Remands Agricultural Land vs Capital Asset Issue – Directs Proper Sec 2(14) Verification

February 19, 2026 756 Views 0 comment Print

ITAT condoned a 106-day delay considering the assessees senior citizen status and bona fide reasons. On merits, it restored the capital gains issue to the Assessing Officer for de novo verification.

ITAT Dehradun Quashes Reassessment – Borrowed Satisfaction, Mechanical Approval & Third-Party Loose Papers Held Insufficient

February 18, 2026 225 Views 0 comment Print

It was ruled that approval under Section 151 granted mechanically, with contradictory stands taken by the authority, vitiates the reopening. The reassessment was set aside for lack of proper application of mind.

ITAT Kolkata Quashed Reopening Because It Was Based on Mere Change of Opinion

February 18, 2026 381 Views 0 comment Print

ITAT Kolkata held that reassessment under Section 147 was invalid as it relied solely on existing records. In absence of new tangible material, reopening amounted to impermissible review.

Reassessment Solely on Audit Objection Invalid; Rule of Law Overrides Revenue Considerations: Delhi HC

February 18, 2026 801 Views 0 comment Print

Delhi High Court held reassessment under Sections 147/148 cannot be initiated merely on an internal audit objection. Absence of new tangible material made reopening invalid.

200% Sec 270A Penalty Valid; Wrong VI-A deduction Misreporting; 270AA Immunity Denied

February 17, 2026 4377 Views 0 comment Print

The Tribunal upheld 200% penalty under Section 270A for misreporting income through ineligible deductions. Admitted incorrect claims were treated as conscious misrepresentation, not a bonafide error.

Reopening Beyond 4 Years Invalid; No Independent Enquiry; LTCG Penny Stock Addition u/s 68 Deleted

February 17, 2026 522 Views 0 comment Print

The Tribunal noted that the AO reopened the case under the mistaken belief that no scrutiny assessment had been made. Such factual error and absence of new incriminating material vitiated the assumption of jurisdiction under Section 147.

Sec 263 Revision Quashed as PCIT Failed to Conduct Independent Enquiry: ITAT Amritsar

February 17, 2026 354 Views 0 comment Print

The AO recorded reasons for escapement without receiving confirmation from the Sub-Registrar. ITAT ruled that absence of tangible evidence vitiated reassessment, making the subsequent Section 263 revision unsustainable.

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