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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


Income estimated at 8% since assessee failed to substantiate its claim of 5%: ITAT Chennai

January 23, 2025 903 Views 0 comment Print

ITAT Chennai held that estimation of 8% as income on the total receipt by AO is justifiable since assessee failed to substantiate its claim of earning 5% commission on total receipt. Accordingly, addition confirmed and appeal dismissed.

ITAT Kolkata deletes Addition for Unexplained Cash Deposit not belonging to Assessee

January 23, 2025 2427 Views 0 comment Print

ITAT Kolkata deletes ₹8.27 lakh addition under Section 69A, ruling cash deposits belonged to Seva Kendra, not the assessee. Penalty also set aside.

Shift from Bogus Purchases to Bogus Sales Violates Principles of Natural Justice: Guwahati HC

January 23, 2025 1809 Views 0 comment Print

Guwahati HC examines violations in Section 148A orders for income tax assessments, directing re-evaluation due to procedural lapses.

ITAT Pune Remands Case for Fresh Adjudication on Commission Income Addition to Gross Receipt

January 23, 2025 735 Views 0 comment Print

ITAT Pune remands the case of Prakash Dipchand Kapadnis, instructing NFAC to reconsider the addition of gross receipts instead of net income for AY 2013-14.

ITAT Allahabad Remands Case Over Fraudulent Cash Deposits

January 23, 2025 1044 Views 0 comment Print

ITAT Allahabad remands ₹45.4 lakh unexplained cash deposit case, citing lack of evidence and claims of fraud. Assessee given a fresh chance to present facts.

ITAT Remands ₹117.01 Lakhs Addition as AO Ignored Assessee’s Details

January 23, 2025 486 Views 0 comment Print

ITAT Chennai remands Rs.117.01 lakh addition for fresh review, citing non-consideration of assessee’s details in assessment.

Penalty Imposed on PCIT and JAO for Mechanical Orders in Reassessment Proceedings

January 22, 2025 2541 Views 0 comment Print

A prior approval was sought to pass the order u/s 148A(d) from the Specified Authority, Principal Commissioner of Income Tax and after receiving the prior approval from the specified authority, an order u/s 148A(d) was passed.

Assessment Issued in Wrong Name Post-Merger Not Correctable Under Section 292B

January 22, 2025 1131 Views 0 comment Print

Despite there was a valid disclosure made by assessee and AO being duly apprised of the factum of merger, AO made the draft assessment order in the name of a party which no longer existed on that date.

Is entity having ‘Permanent Establishment’ was a fact-specific issue to be determined separately for different tax periods

January 22, 2025 822 Views 0 comment Print

Whether or not a permanent establishment existed in a State during a given period must be determined on the basis of the circumstances applicable during that period and not those applicable during a past or future period.

ITAT Restores ₹10 Lakh Section 35AC Donation Disallowance to AO

January 21, 2025 840 Views 0 comment Print

ITAT Ahmedabad remands ₹10 lakh donation disallowance under Section 35AC to AO for reassessment. Assessee’s appeal partially allowed for statistical purposes.

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