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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


Bogus Purchase Addition Deleted – Suspicion from STR Report Insufficient When Purchases Supported by Evidence

March 13, 2026 645 Views 0 comment Print

ITAT Bangalore held that the Assessing Officer must establish bogus purchases with cogent evidence before making additions. Since the assessee produced complete records and the AO found no defects, the entire addition was deleted.

Reassessment Quashed as Time-Barred – Fresh Notice U/s 148 Issued Beyond Surviving Period After Ashish Agarwal Judgment

March 13, 2026 513 Views 0 comment Print

The Tribunal found that the Assessing Officer failed to issue the fresh notice within the surviving limitation period recognized by the Supreme Court. The reassessment order was therefore quashed.

Reassessment Quashed – Mechanical Approval U/s 151 Based on Wrong Fact that Assessee Was a Non-Filer

March 13, 2026 417 Views 0 comment Print

ITAT Bangalore held that reassessment proceedings were invalid where approval under Section 151 was granted mechanically. The sanction was based on the incorrect assumption that the assessee had not filed a return.

ITAT Chennai Quashes U/s 153A Additions Based Only on Special Audit Findings

March 13, 2026 222 Views 0 comment Print

The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.

Assessment in the Name of Deceased Person – Absence of Notice to Legal Heir – Entire Assessment Held Void: ITAT Bangalore

March 12, 2026 4788 Views 0 comment Print

Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.

Oracle India P. Ltd. not permanent establishment of Oracle Systems Corporation

March 11, 2026 510 Views 0 comment Print

ITAT Delhi held that Oracle India Private Limited is an independent legal entity and existence of Oracle India Private Limited cannot be considered as permanent establishment of Oracle Systems Corporation. Hence, there is not question of attribution of profit to Permanent Establishment.

Section 68 Addition Cannot Be Sustained When Loans Are Received and Repaid Through Banking Channels

March 10, 2026 7128 Views 0 comment Print

ITAT Delhi deleted additions under Sections 68 and 69C after finding that the assessee received and repaid loans through banking channels with supporting confirmations and evidence.

ITAT Upholds Assessment Because Larger Bench Decision of HC Must Be Preferred Over Single Judge View

March 9, 2026 318 Views 0 comment Print

The ITAT held that when non-jurisdictional High Courts give conflicting decisions, a division bench ruling should be preferred over a single judge decision. On that basis, the Tribunal rejected the assessee’s claim that the assessment order was time-barred.

Reassessment Notice Upheld Because AO Followed CBDT and SC Directions

March 9, 2026 429 Views 0 comment Print

ITAT held that the reassessment notice issued under Section 148 was valid because the Assessing Officer followed CBDT Instruction 1/2022 and the Supreme Court’s decision on reassessment procedures. The Tribunal rejected the argument that the notice was barred by limitation.

Reassessment Notice Invalid as It Was Issued to Non-Existent Entity: Bombay HC

March 9, 2026 357 Views 0 comment Print

The Bombay High Court quashed reassessment proceedings for AY 2018-19 after finding that the notice under Section 148 was issued in the name of an entity that had already merged and ceased to exist.

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