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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


Reassessment Notice Quashed Because It Was Issued Beyond Limitation: Bombay HC

March 9, 2026 645 Views 0 comment Print

The Bombay High Court held that the reassessment notice under Section 148 was issued after the surviving limitation period expired. As a result, the entire reassessment proceedings and assessment order were quashed.

TDS Default Order Time-Barred as Limitation Must Be Computed Quarter-Wise, Not Annually

March 9, 2026 432 Views 0 comment Print

The Bombay High Court ruled that limitation under Section 201(3) must be calculated based on the financial year in which each quarterly TDS statement is filed. The decision confirms that annual or cumulative computation of limitation is not permitted.

Parallel Assessment Proceedings Illegal, ITAT Quashes Reassessment Order in Case of Lalit Modi

March 9, 2026 783 Views 0 comment Print

ITAT Delhi held that reassessment proceedings under Section 147 cannot be initiated while scrutiny assessment under Section 143(2) is still pending. Such parallel proceedings are without jurisdiction and render the entire reassessment order invalid.

Reassessment Quashed as Section 148 Notice Was Issued by JAO Instead of FAO

March 8, 2026 1116 Views 0 comment Print

ITAT Hyderabad held that reassessment proceedings were invalid because the notice under Section 148 was issued by the jurisdictional officer rather than through the mandatory faceless system. The assessment order was quashed for lack of jurisdiction.

Reassessment Quashed Because Notice Issued to Non-Existent Company After LLP Conversion

March 8, 2026 708 Views 0 comment Print

ITAT Delhi held that reassessment proceedings are invalid when notice under Section 148 is issued in the name of a company that had already converted into an LLP. The Tribunal ruled that proceedings against a non-existent entity are void in law.

Reassessment Notice Issued to Deceased Person Invalid – Entire Proceedings u/s 147 Quashed – ITAT Bangalore

March 7, 2026 624 Views 0 comment Print

The Tribunal ruled that reassessment proceedings initiated against a dead person are void in law. A valid notice must be issued to the legal heirs under Section 159 before initiating reassessment.

Cash Deposits in Partner’s Personal Bank Account Explained as Firm’s Business Receipts – Addition U/s 69A Deleted

March 7, 2026 603 Views 0 comment Print

The Tribunal ruled that cash deposits routed through a partners personal bank account were explained as firms business receipts. Without evidence of undisclosed sources, Section 69A addition cannot be made.

Section 11 Benefit Depends on Cost-Based Pricing Because Profit Motive Matters: ITAT Raipur

March 5, 2026 321 Views 0 comment Print

The tribunal held that exemption for a statutory housing authority depends on whether housing units were sold above cost. The case was remanded to examine if charges exceeded cost plus nominal mark-up.

Sec 44AD: Cash Deposits Within Turnover Not Unexplained; ITAT Deletes Additions Based Only on Survey Statement

March 5, 2026 483 Views 0 comment Print

The Tribunal held that cash deposits cannot be treated as unexplained when they fall within accepted business turnover declared under the presumptive taxation scheme. Once turnover is accepted under Section 44AD, separate additions for such deposits are generally not justified.

ITAT Sets Aside ₹169.75 Cr Addition Because Parallel Proceedings Arose After Reassessment Was Set Aside

March 5, 2026 1776 Views 0 comment Print

The Tribunal ruled that simultaneous proceedings arising from reassessment and revision for the same year could lead to multiplicity of proceedings and inconsistent findings. It restored the entire matter to the Assessing Officer for consolidated de-novo adjudication.

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