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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


ITAT Remands Case to AO, Allows Assessee to Explain Investments

January 21, 2025 513 Views 0 comment Print

ITAT Ahmedabad order in Maheshbhai Nagjibhai Desai Vs ITO case, addressing reopening under Section 147 and unexplained investments under Section 69.

ITAT Ahmedabad Remands Case on Unexplained Investments to AO

January 21, 2025 576 Views 0 comment Print

ITAT Ahmedabad remands case on unexplained investments of ₹18.19L in land & shares. Tribunal directs re-examination by AO after Assessee presents evidence.

No power to Designated Authority to reopen concluded cases under Vivad se Vishwas Act

January 20, 2025 1314 Views 0 comment Print

There was no provision under the DTVSV Act that empowered a Designated Authority to reopen a concluded settlement. Once a final certificate was issued under Section 5(1), all disputes with regard to the ‘tax arrear’ stood concluded.

Addition on grounds not forming part of reasons recorded for reopening of assessment not tenable

January 20, 2025 810 Views 0 comment Print

ITAT Ahmedabad held that addition on grounds other than grounds forming part of reasons recorded for reopening of assessment not justified. Accordingly, addition towards unexplained investment which didn’t form part of reasons liable to be deleted.

Ground not addressed by CIT(A) cannot be taken up by ITAT: Delhi HC

January 20, 2025 768 Views 0 comment Print

Delhi High Court held that ITAT cannot address the ground which remained unaddressed by CIT(A). Accordingly, matter restored back to CIT(A) to decide on the grounds that were not decided.

Provision for leave salary not allowable as deduction u/s. 43B(f): Madras HC

January 18, 2025 2289 Views 0 comment Print

Madras High Court held that provision for leave salary is not allowable as deduction under section 43B(f) of the Income Tax Act since deduction of actual payment is allowable and not of provision. Accordingly, question of law answered in favour of revenue.

Both the parties agreed to treat the addition as business receipts: ITAT directed AO to assess profit @ 8%

January 18, 2025 1842 Views 0 comment Print

Assessee didnot file return for the year under consideration. As per AIMS module information received that assessee has deposited the amount of Rs.16,84,100/- as cash during the demonetization period. Case was reopened notice was issued accordingly.

S.159 applies when reassessment notice was issued during lifetime of deceased assessee

January 18, 2025 1974 Views 0 comment Print

In response to the said notice, the son/legal heir of the deceased assessee submitted a reply on 01 April 2023 wherein he unequivocally apprised the respondent of the demise of his father/assessee, furnishing alongwith a copy of the death certificate as conclusive evidence, and asserted that the notice was null and void ab initio.

ITAT Grants Assessee Another Opportunity Due to Health & Personal Challenge

January 18, 2025 714 Views 0 comment Print

ITAT Ahmedabad allows Pankajkumar Patel’s appeal for statistical purposes, remanding unexplained investment case to AO for reconsideration under Section 69A.

ITAT Reduces Gross Margin on Unaccounted Cash Receipts to 6% Considering All Facts

January 18, 2025 909 Views 0 comment Print

Summary of appeal challenging CIT(A) order on income tax assessment for AY 2013-14. Key issues include Section 147 validity and profit estimation.

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