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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


Reassessment not valid if no application of mind by AO: ITAT Pune

March 2, 2025 1188 Views 0 comment Print

Aadhunik Infrastructure Development Pvt. Ltd. Vs DCIT (ITAT Pune) The Income Tax Appellate Tribunal (ITAT), Pune Bench “A,” has ruled in favor of Aadhunik Infrastructure Development Pvt. Ltd. (formerly Gauri Plasticulture Pvt. Ltd.), setting aside the reassessment proceedings initiated under Section 147 of the Income Tax Act, 1961, for the Assessment Year 2012-13. The appeal […]

Capital gain cannot be treated as bogus merely on warning letter of SEBI without any incriminating material

February 28, 2025 2358 Views 0 comment Print

ITAT Chandigarh held that treating capital gains earned on sale of shares as bogus merely on the basis of warning letter of SEBI without any incriminating material found during course of search demonstrating transaction as bogus is unjustified.

No Reassessment After 4 Years for AO’s Error in Computing Income When Material Facts Fully Disclosed

February 28, 2025 1659 Views 0 comment Print

Bombay High Court invalidates reassessment notice under Section 148 of the Income Tax Act, citing failure to meet jurisdictional conditions under Section 147.

Initiation of revision proceedings u/s. 263 based on audit objection not tenable in law: ITAT Jaipur

February 28, 2025 1392 Views 0 comment Print

ITAT Jaipur held that exercise of revisionary power under section 263 of the Income Tax Act on the basis of audit objection is not tenable in law. Accordingly, initiation of proceedings liable to be quashed.

Order passed u/s. 148A(d) beyond 3 years with approval of PCIT instead of PCCIT quashed

February 28, 2025 1824 Views 0 comment Print

ITAT Pune held that approval of Principal Chief Commissioner of Income Tax [PCCIT] required for order passed under section 148A(d) of the Income Tax Act beyond three years from the end of assessment year.

No Reassessment on Change of Opinion or Solely on Insight Portal Data: Gujarat HC

February 28, 2025 1458 Views 0 comment Print

Gujarat High Court sets aside reassessment notice under Section 148 issued to Khushboo Anand Bhayani for F&O trading profits, citing lack of independent verification.

Section 69 Addition: ITAT Directs CIT(A) to Reassess Case & Consider Additional Evidence

February 28, 2025 2310 Views 0 comment Print

ITAT Ahmedabad remands case due to incorrect notice delivery, allowing reassessment of unexplained deposits and income under natural justice principles.

Substantive Additions Require Evidence; Protective Additions Apply to Ownership Uncertainty

February 27, 2025 882 Views 0 comment Print

ITAT Ahmedabad rules on undisclosed foreign accounts in the case of Manjulaben Bipinbhai Patel vs DCIT, addressing tax assessments and legal implications.

Rajasthan HC quashes section 148 notice for Vague & Incomplete Information

February 27, 2025 1944 Views 0 comment Print

Rajasthan High Court quashes IT notice against Prateek Bulls and Bears Pvt Ltd due to lack of evidence linking bank account to the assessee. 

Reassessment Invalid without Fresh Notice when No Addition made on Reopened Issue: ITAT Pune

February 27, 2025 768 Views 0 comment Print

ITAT Pune held that when no addition has been made on account of which the case was reopened, the Assessing Officer cannot make any other addition without issuing a fresh notice u/s 148 of the Act.

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