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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 4389 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


Reversal of Previously Disallowed Securitisation Provisions Cannot Be Taxed Again: ITAT Mumbai

Income Tax : The Mumbai ITAT held that reversal of securitisation provisions already disallowed in earlier years cannot be taxed again upon wri...

May 21, 2026 66 Views 0 comment Print

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 102 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 81 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 162 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


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 10305 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


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.

ITAT Mumbai: Second Reopening Based on Same Material Is Invalid-Change of Opinion Not Permissible

April 13, 2026 258 Views 0 comment Print

The Tribunal ruled that reassessment cannot be reopened on issues already examined earlier. It held that absence of fresh material and mere change of opinion renders reopening invalid.

ITAT Mumbai: Reopening Invalid Without Proper Sanction-Approval by Wrong Authority Vitiates Entire Proceedings

April 13, 2026 300 Views 0 comment Print

ITAT Mumbai holds reassessment invalid where approval under Section 151 was obtained from incorrect authority, ruling defect as jurisdictional and quashing notice under Section 148 and consequent proceedings.

ITAT Mumbai: Reopening Beyond 3 Years Invalid Where Escaped Income below ₹50L-Notice u/s 148 Quashed

April 13, 2026 291 Views 0 comment Print

ITAT Mumbai quashes reopening beyond 3 years where escaped income is below ₹50 lakh, holding notice under Section 148 time-barred and invalid, thereby deleting consequential addition.

ITAT Mumbai: Reopening Invalid Without Proper Sanction-Entire Assessment Quashed

April 13, 2026 588 Views 0 comment Print

ITAT Mumbai quashed reassessment as approval under Section 151 was obtained from the wrong authority. Notice under Section 148 held invalid, making entire proceedings void ab initio.

Reassessment Quashed as Time-Barred Due to Post-2021 Notice for AY 2015–16

April 11, 2026 708 Views 0 comment Print

The Tribunal invalidated reassessment proceedings since the Section 148 notice was issued after 01.04.2021, making it time-barred. The ruling reinforces strict limitation compliance for reopening cases.

No Section 68 Addition on Sales Already Offered to Tax: ITAT Mumbai

April 10, 2026 456 Views 0 comment Print

The Tribunal held that recorded sales forming part of turnover cannot be treated as unexplained cash credits. The key takeaway is that taxing gross sales again is impermissible in law.

Reopening Invalid as Based on Issue Already Decided in Earlier Year: Gujarat HC

April 10, 2026 327 Views 0 comment Print

The case examined reopening based on a prior disallowance under Section 80IB(10). The Court found that the disallowance had already been reversed by appellate authorities. Therefore, reopening based on the same ground was held invalid.

Non-service of statutory notice prior to initiation of proceedings u/s. 148 not tenable: Matter remitted

April 10, 2026 261 Views 0 comment Print

Orissa High Court held that assessment order set aside as proceedings under section 148 of the Income Tax Act initiated without serving of statutory notice. Accordingly, matter remitted back to AO to serve notice u/s. 148 as not hit by limitation u/s. 149.

Unexplained Cash Deposits Addition Reduced Because Only Peak Balance Taxable: ITAT Ahmedabad

April 10, 2026 480 Views 0 comment Print

ITAT confirmed validity of reassessment based on cash deposit information. However, it reduced addition by applying peak credit theory due to withdrawal patterns

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