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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


Requirement to explain ‘source of source’ was restricted to Share Capital and couldn’t be extended to unsecured Loans

February 2, 2025 2607 Views 0 comment Print

Assessee had satisfactorily explained the source of credits in his books and consequently, CIT(A) had rightly deleted the additions after relying on various judgments made by AO.

Denial of exemption u/s. 54B for purchase of agricultural land in name of wife not justified

February 1, 2025 933 Views 0 comment Print

ITAT Delhi held that denial of exemption under section 54B of the Income Tax Act for purchase of agricultural land in the name wife of the assessee is not justifiable. Accordingly, denial of benefit of deduction set aside.

Exemption Under Section 54F Allowed Even If Claimed Post section 148 notice

February 1, 2025 2034 Views 0 comment Print

ITAT Visakhapatnam rules exemption under Section 54F can be claimed even if made after a notice under Section 148 of the Income Tax Act.

AO who issued notice u/s. 148 of old Act is required to pass an order under new scheme

January 31, 2025 1176 Views 0 comment Print

Punjab and Haryana High Court held that the same assessing officer is required to pass an order under the new scheme after giving notice under Section 148 of the old Act. Thus, all the writ petition are dismissed.

Reopening solely relying upon information without forming independent opinion is liable to be quashed

January 31, 2025 498 Views 0 comment Print

Gujarat High Court held that AO couldn’t assume jurisdiction to reopen assessment, without forming independent opinion, solely and mechanically relying upon the information received from the other sources. Accordingly, reopening u/s. 148 quashed.

Rejection of renewal of exemption u/s. 80G without substantial evidence is not tenable

January 30, 2025 846 Views 0 comment Print

Punjab and Haryana High Court held that rejection of claim of exemption under section 80G not based upon any substantial evidence is not tenable in law. Accordingly, writ petition is allowed.

Assessee engaged in business of cheque discounting: ITAT estimated 10 % of total cash deposit

January 30, 2025 933 Views 0 comment Print

Assessee didnot file ITR for AY 2012-13 during which assessee made cash deposit of Rs.45,69,722/-. The case was reopened and notice u/s 148 was sent through e-mail against which no ITR was filed. Hence, AO made addition u/s 69A.

Unexplained cash deposit matter restored hence corresponding penalty u/s. 271(1)(c) matter too restored

January 30, 2025 780 Views 0 comment Print

ITAT Agra held that matter of levying penalty u/s. 271(1)(c) of the Income Tax Act restored back to file of AO since Tribunal restored matter of addition towards unexplained cash deposit for quantification.

Cash Deposits during Demonetization: ITAT Upholds ₹1.10 Cr Addition

January 30, 2025 2547 Views 0 comment Print

ITAT Patna’s decision in Dharmendra Kumar vs. ITO regarding ₹1.10 crore treated as unexplained income. Appeal dismissed due to non-compliance.

Section 263 notice is invalid if the original order ceases to exist: ITAT Jaipur

January 29, 2025 1878 Views 0 comment Print

Detailed analysis of the ITAT Jaipur decision in Dinesh Kumar Chaurasia Vs ACIT on unexplained investments, Section 263 jurisdiction, and procedural lapses.

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