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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 2841 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 57 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 96 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 66 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 84 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 447 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 5742 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


ITAT Delhi Quashes Reassessment Because Section 148 Notice Was Issued to Deceased Assessee

March 15, 2026 1341 Views 0 comment Print

ITAT ruled that jurisdiction to reopen assessment arises only when a valid notice is issued to a living person or legal representative. Since the notice was issued to a deceased assessee, the reassessment order was declared illegal.

LTCG Cannot Be Taxed in Wife’s Hands When Property Settled by Husband – ITAT Deletes Rs. 19.86 Cr Addition

March 14, 2026 9075 Views 0 comment Print

The Tribunal held that capital gains from property transferred to a spouse without consideration must be taxed in the hands of the transferor under Section 64(1)(iv). Assessing it again in the transferee spouse’s hands was invalid.

ITAT Pune: Reopening After 4 Years Invalid When Share Premium Details Already Disclosed – Rs. 30 Cr Addition u/s 68 Deleted

March 14, 2026 402 Views 0 comment Print

The Tribunal held that reopening an assessment after four years is invalid when the assessee has fully disclosed all material facts during the original scrutiny. The reassessment was quashed for lack of new material evidence.

Reassessment Quashed – Notice U/s 148 Held Time-Barred & Ante-Dated

March 14, 2026 4830 Views 0 comment Print

The tribunal noted discrepancies in the dispatch register used to prove issuance of the notice. Because the records did not inspire confidence, the tribunal held the reassessment notice to be time-barred.

ITAT Chennai Quashes Reassessment – Notice U/s 148 Invalid for Want of Approval from Correct Authority U/s 15

March 13, 2026 435 Views 0 comment Print

The Tribunal held that a notice under section 148 issued beyond three years requires sanction from PCCIT under section 151(ii). Approval from PCIT was held insufficient, leading to quashing of the reassessment.

ITAT Pune: Entire Bank Deposits Cannot Be Taxed – Income to Be Estimated @2% on Deposits in Renukamata Society Account

March 13, 2026 648 Views 0 comment Print

The Tribunal held that entire bank deposits cannot automatically be treated as unexplained income under Section 69A. Instead, where deposits relate to commission-based transactions, only a reasonable profit percentage (2% of deposits) should be taxed.

Expenditure Cannot Be Disallowed Solely for Non-Response to Notices U/s 133(6); Matters Remanded for Proper Verification

March 13, 2026 600 Views 0 comment Print

The Tribunal held that mere non-response to notices issued to vendors cannot justify disallowance of large business expenses when documentary evidence and accepted turnover exist. The issue was remanded to the Assessing Officer for proper verification.

CIT(A) Cannot Admit Fresh Evidence Without AO’s Opportunity – Violation of Rule 46A; Matter Remanded

March 13, 2026 273 Views 0 comment Print

The Tribunal ruled that admitting additional evidence without seeking a remand report from the Assessing Officer breaches Rule 46A. The matter was sent back to the AO for reconsideration after examining the evidence.

Reassessment Quashed – Notice U/s 148A(b) Invalid for Granting Less Than Mandatory 7 Days to Reply

March 13, 2026 657 Views 0 comment Print

The Tribunal ruled that Section 148A(b) requires a minimum of seven days for the assessee to respond. Failure to grant this statutory period renders the notice and subsequent reassessment proceedings illegal.

Additions Cannot Survive When Reassessment Is Quashed by High Court – Revenue’s Appeal Dismissed

March 13, 2026 267 Views 0 comment Print

The Tribunal held that once the High Court quashed the reassessment for being based on a change of opinion, the additions made in those proceedings could not survive.

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