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Section 147

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Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...

May 13, 2026 390 Views 0 comment Print

CIT(A) cannot enhance income on issues not examined by AO: ITAT Mumbai

Income Tax : The Tribunal held that CIT(A) cannot enhance income under Section 251 on matters not considered by the Assessing Officer during as...

May 10, 2026 573 Views 0 comment Print

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 729 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 1032 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 3180 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 2277 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 4386 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 7494 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 13344 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 42813 Views 2 comments Print


Latest Judiciary


ITAT Mumbai Quashes Reassessment as Section 148 Notice Was Issued Beyond Surviving Limitation Period

Income Tax : ITAT Mumbai held that the reassessment notice issued on 24.07.2022 was time-barred under the Supreme Court ruling in Rajeev Bansal...

May 20, 2026 84 Views 0 comment Print

ITAT Delhi Quashes Reassessment as Reopening Was Based Only on Audit Objection

Income Tax : The Delhi ITAT held that reassessment proceedings initiated solely on the basis of a revenue audit objection without fresh tangibl...

May 20, 2026 78 Views 0 comment Print

Reassessment Quashed as AO Used Section 147 Instead of Mandatory Section 153C

Income Tax : ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 15...

May 20, 2026 141 Views 0 comment Print

Section 263 Proceedings Quashed as AO’s Order Was Not Erroneous in Jewellery Case

Income Tax : The Tribunal held that the reassessment order could not be revised under Section 263 since the conditions for treating jewellery e...

May 20, 2026 93 Views 0 comment Print

Bangalore ITAT Grants Relief in Section 50C Addition – DVO Valuation in Co-Owner’s Case Accepted Over Stamp Duty Value

Income Tax : The ITAT ruled that the Assessing Officer wrongly adopted the stamp duty valuation despite contrary valuation material on record. ...

May 20, 2026 111 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 5817 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 846 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 10302 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 5892 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 5907 Views 0 comment Print


ITAT Ahmedabad: No Penalty for Mere Wrong Claim – U/s 271(1)(c) Deleted

April 14, 2026 183 Views 0 comment Print

The issue was whether incorrect tax treatment amounts to concealment. The Tribunal held that mere wrong classification in books does not attract penalty under Section 271(1)(c).

ITAT Mumbai: Section 68 Addition Deleted – Mere Suspicion & Third-Party Info Not Enough

April 14, 2026 234 Views 0 comment Print

The issue was whether addition can be made based on third-party investigation findings. The Tribunal held that without direct incriminating evidence, such addition is unsustainable, emphasizing the need for nexus.

ITAT Delhi: No Proper Service of U/s 148 Notice – Entire Reassessment Quashed

April 14, 2026 258 Views 0 comment Print

The issue was whether reassessment is valid without proper service of notice. The Tribunal held that absence of valid service makes the entire reassessment void and unsustainable.

ITAT Mumbai: No Penalty U/s 271(1)(c) on Estimated Bogus Purchase Additions

April 13, 2026 504 Views 0 comment Print

The Tribunal held that penalty under Section 271(1)(c) cannot be imposed when additions are made on an estimated basis. It upheld deletion of penalty, emphasizing absence of concrete evidence of concealment.

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

April 13, 2026 705 Views 0 comment Print

The Tribunal clarified that filing of original return is not mandatory for claiming exemption under Section 54. It directed verification of conditions and allowed relief if eligibility is established.

Reassessment Invalid Due to Change of Opinion on Same Facts: ITAT Mumbai

April 13, 2026 348 Views 0 comment Print

The Tribunal held that reopening an assessment on identical material already examined is invalid. It ruled that reassessment cannot be used to revisit concluded issues without fresh evidence.

ITAT Mumbai Quashes Reopening: Approval by Wrong Authority u/s 151 Makes Entire Reassessment Void

April 13, 2026 342 Views 0 comment Print

The case addresses whether reassessment is valid when approval is granted by the wrong authority. ITAT held that sanction under Section 151 is jurisdictional and must be from the correct authority. The entire reassessment was quashed for non-compliance.

ITAT Pune: No Penalty When Mistake Attributable to Tax Consultant – Bona Fide Conduct Accepted

April 13, 2026 882 Views 0 comment Print

ITAT held that penalty cannot be imposed where incorrect return was due to consultant’s misconduct. The ruling highlights that bona fide mistakes with voluntary tax payment negate penalty.

ITAT Mumbai: Reopening Invalid on Change of Opinion-No Fresh Material, Assessment Quashed

April 13, 2026 246 Views 0 comment Print

ITAT held reassessment invalid as it was based on already examined facts without fresh material. The ruling reinforces that reopening on mere change of opinion is not permissible.

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

April 13, 2026 378 Views 0 comment Print

ITAT held that section 249(4) cannot be invoked where no taxable income arises in India. Appeals must be decided on merits rather than dismissed on technical grounds.

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