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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


Income Tax Reassessment Quashed: Change of Opinion Illegal

March 14, 2025 654 Views 0 comment Print

Madras HC voids reassessment, ruling change of opinion beyond 4 years is illegal. No non-disclosure by Saravana Stocks found.

No Section 271(1)(c) Penalty on Voluntary Income Disclosure: ITAT Visakhapatnam

March 13, 2025 1584 Views 0 comment Print

ITAT Visakhapatnam ruled no penalty for voluntary income disclosure post-survey, rejecting AO’s concealment claims.

IT Reassessment Notice Beyond TOLA’s Limitation Period Invalid: ITAT Mumbai

March 11, 2025 1860 Views 0 comment Print

ITAT Mumbai quashes reassessment against CLE Private Limited, ruling notice issued beyond TOLA’s limitation period is invalid.

Reassessment Beyond 4 Years Requires failure to disclose material facts: Bombay HC

March 11, 2025 891 Views 0 comment Print

Learn about the Bombay High Court’s decision in Crystal Pride Developers vs ACIT regarding reassessment beyond 4 years under Section 147 of the IT Act, emphasizing the necessity of disclosing material facts. Understand the legal implications and judicial precedents involved.

Addition u/s. 68 restricted to 0.30% of total Circular Trading Transaction: ITAT Ahmedabad

March 10, 2025 1704 Views 0 comment Print

ITAT Ahmedabad held that CIT(A) rightly restricted disallowance on account of unexplained bank deposit and withdrawal under section 68 of the Income Tax Act to 0.3% of total Circular Trading Transaction. Accordingly, appeal of revenue dismissed.

Reassessment not Change of Opinion if original assessment not involve any formation of opinion

March 10, 2025 489 Views 0 comment Print

It was held that in the original assessment under Section 143(1), the issue related to the deed of purchase of land was not looked into as the same was not reported in the assessee’s income before the Revenue.

Reassessment notice issued u/s. 148 beyond six years is time barred: ITAT Mumbai

March 10, 2025 8130 Views 0 comment Print

ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. Accordingly, assessment proceedings under section 147 is liable to be quashed.

ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

March 9, 2025 549 Views 0 comment Print

ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh assessment by the AO.

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

March 9, 2025 759 Views 0 comment Print

ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof.

ITAT Surat Directs Re-examination of Tax on Gift from HUF

March 9, 2025 861 Views 0 comment Print

ITAT Surat remands case to CIT(A) for fresh adjudication on HUF gift taxability under Section 56(2)(vii) of the Income Tax Act, citing judicial precedents.

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