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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


Madras HC directed to challenge assessment and rectification order before CIT(A)

April 10, 2025 453 Views 0 comment Print

Madras High Court disposed of the writ petition with direction to petitioner to challenge the impugned Assessment Order as well as Rectification Order before Commissioner of Income Tax (Appeals) [CIT(A)].

Reassessment u/s. 148 is invalid if based on borrowed satisfaction: ITAT Hyderabad

April 10, 2025 2391 Views 0 comment Print

ITAT Hyderabad held that re-assessment under section 148 merely based on borrowed satisfaction, without any independent verification and application of mind, is invalid and liable to be quashed. Accordingly, notice u/s. 148 and consequent order quashed.

Section 148 Reopening unsustainable as material facts fully & truly disclosed: Madras HC

April 10, 2025 972 Views 0 comment Print

Madras High Court held that re-opening u/s. 148 read with section 147 of the Income Tax Act not sustained as there is no failure on the part of assessee to fully and truly disclosure all the material facts. Thus, notice and order quashed.

No jurisdictional error if Faceless Assessment Procedure prescribed followed: Patna HC

April 10, 2025 2316 Views 0 comment Print

Patna High Court held that Faceless Assessment Procedure as prescribed under section 144B of the Income Tax Act is duly followed and in course of faceless assessment at every stage approval from competent authorities have been obtained.

ITAT Orders Fresh Examination of ST Doctor’s Tax Exemption Claim U/S 10(26)

April 10, 2025 777 Views 0 comment Print

ITAT Kolkata overturns CIT(A) order on tribal doctor’s tax exemption, orders re-examination of income sources and bank deposits under Section 10(26).

Correspondence with CA Does Not Justify Notices to Deceased Person: Bombay HC

April 10, 2025 7770 Views 0 comment Print

Bombay HC quashes tax notices issued to deceased Amjad Ahmed Shaikh. Court emphasizes notices to dead are void, allowing fresh action. The court dismissed revenue’s explanation regarding correspondence with the chartered accountant, stating it did not justify issuing notices to a deceased person.

Section 151A: JAO Lacks Jurisdiction to Issue Section 148 Income Tax Notices

April 9, 2025 7296 Views 1 comment Print

Rajasthan High Court held that, in terms of section 151A of the Income Tax Act, Jurisdictional Assessing Officer [JAO] doesn’t have jurisdiction to issue notices under section 148 of the Income Tax Act. Accordingly, notices u/s. 148 are liable to be quashed.

Single Satisfaction Note under Section 153C for Multiple Years is invalid: Karnataka HC

April 8, 2025 1551 Views 0 comment Print

Karnataka HC rules single tax ‘satisfaction note’ invalid for multiple years. Separate notes required under Section 153C, impacting tax assessments.

Revision u/s. 263 based on audit objection impermissible: ITAT Chandigarh

April 8, 2025 1116 Views 0 comment Print

ITAT Chandigarh held that initiation of revisionary proceedings under section 263 of the Income Tax Act on the basis of audit objection is not permissible. Accordingly, order of PCIT quashed and appeal of assessee allowed.

ITAT Deletes ₹8.01 Crore Section 68 Addition on Penny Stock Transactions

April 8, 2025 8151 Views 0 comment Print

ITAT Mumbai allows Sejal Jignesh Shah’s appeal against tax additions under Section 68, rejecting AO’s reliance on investigation reports in a penny stock case.

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