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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


ITAT Mumbai Restores Income Tax Appeal due to Lack of Meritorious Adjudication

April 17, 2025 1047 Views 0 comment Print

ITAT Mumbai remands case of Sandeep Singh Karhail vs Girish Agrawal for fresh hearing, citing lack of opportunity and procedural lapses in reassessment.

Reassessment proceeding u/s. 148 quashed as based on change of opinion

April 17, 2025 861 Views 0 comment Print

The petitioner filed its return of income u/s 139(1) of the Act on 24 November 2014 which was subsequently revised on two occasions namely on 17 March 2016 and 25 March 2016 which was further modified on 29 November 2016.

Reassessment u/s. 147 without any fresh material not sustainable: ITAT Raipur

April 16, 2025 1041 Views 0 comment Print

ITAT Raipur held that reassessment proceedings under section 147 of the Income Tax Act without any fresh material, amounts to mere change of opinion, and hence the same is not sustainable in law.

ITAT Delhi quashes reassessment order as Section 148 notice sent to wrong email ID

April 16, 2025 7431 Views 0 comment Print

ITAT Delhi quashes reassessment order against Nitin Jain due to invalid service of notice under Section 148, sent to the wrong email ID.

ITAT Jaipur Remands Capital Gains Case to AO for Fresh Hearing

April 16, 2025 738 Views 0 comment Print

ITAT Jaipur allows Ashok Kumar Jain’s appeal for statistical purposes, remanding capital gains issue to AO for reconsideration with due process.

Perfunctory or mechanical approvals under Section 151 are invalid: ITAT Delhi

April 16, 2025 3201 Views 0 comment Print

ITAT Delhi cancels reassessment in Jagbir Singh’s case due to invalid approval under Section 151. Legal jurisdiction under Section 147 found to be flawed.

Reassessment Void as Reopening Initiated by Officer Without Jurisdiction: ITAT Delhi

April 16, 2025 933 Views 0 comment Print

ITAT Delhi sets aside reassessment order against Tirlok Singh citing jurisdictional errors in notice issued under Section 148 by ITO Kurukshetra.

Reopening based on incorrect fact understanding is unsustainable: ITAT Mumbai

April 14, 2025 1797 Views 0 comment Print

ITAT Mumbai held that the very basis of which the Assessing Officer formed the belief that the income liable to tax is escaped assessment was based upon incorrect understanding of the facts and is, therefore, not sustainable in the eyes of law.

No addition sustains if addition based on which reasons recorded for reopening got deleted

April 14, 2025 1431 Views 0 comment Print

Delhi High Court held that once addition on the basis of which reasons recorded for reopening of assessment under section 147 of the Income Tax Act has been deleted, then, other addition made are not sustainable in law. Accordingly, appeal allowed.

Section 151A effective from 29.03.2022; jurisdiction under faceless assessment scheme not applicable prior

April 14, 2025 2640 Views 0 comment Print

ITAT Kolkata held that assumption of jurisdiction to impugned assessment under faceless assessment scheme prior to 29.03.2022 when provisions of section 151A of the Income Tax Act had not come into operation is not sustainable and without jurisdiction. Accordingly, appeal of assessee allowed.

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