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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


Reassessment Based on Insight Portal Info Must Be Under Sections 147/148 if Section 153C Jurisdictional Conditions Are Not Met

December 20, 2024 1899 Views 0 comment Print

Assessee argued that AO lacked jurisdiction to initiate proceedings under Section 147/148 as the information derived from the search should had been assessed under Section 153C.

Matter was remanded as non-compliance was due to Karta of HUF died and notices sent to an outdated address

December 19, 2024 1080 Views 0 comment Print

Assessee challenged an income tax assessment order under Section 147 read with Section 144. Assessee represented a Hindu Undivided Family (HUF) who was Karta, Mr. M. Subramanian passed away on 15.01.2013.

Notice issued u/s. 148 after period of six years for AY 2015-16 is barred by limitation: ITAT Mumbai

December 19, 2024 35484 Views 0 comment Print

ITAT Mumbai held that validity of notice issued under section 148 of the Income Tax Act for AY 2015-16 is six year which expires on 31.03.2022. Accordingly, notice issued on 29.07.2022 u/s. 148 is barred by limitation.

Reassessment was valid as Section 147 And 153C could be applied interchangeably

December 19, 2024 1134 Views 0 comment Print

Assessee had not challenged the validity of reopening, though for the first time, assessee had challenged the action of AO by taking plea that AO should have assessed assessee under section 153C and not section 147/148.

Cost imposed on assessee for non-compliance with show cause notice: ITAT Ahmedabad

December 17, 2024 564 Views 0 comment Print

ITAT Ahmedabad imposed cost of Rs. 10,000 on the assessee due to non-compliance with the show cause notice and directed to restore the matter back to the file of Jurisdictional Assessing Officer.

Reopening of unabated assessment u/s. 153A without incriminating material is impermissible

December 17, 2024 1197 Views 0 comment Print

ITAT Kolkata held that in terms of block assessment under section 153A of the Income Tax Act, reopening of unabated assessment without any incriminating material found with respect to concerned assessment year is impermissible in law.

Addition of gift received from son solely relying on unverified newspaper unsustainable: ITAT Mumbai

December 17, 2024 579 Views 0 comment Print

ITAT Mumbai held that addition u/s. 68 towards amount received as gift from son not justified since addition is made in a baseless manner, solely relying on unverified newspaper reports. Accordingly, appeal of revenue dismissed.

Delay in appeal due to attachment of office sufficient cause: ITAT Surat

December 17, 2024 429 Views 0 comment Print

ITAT Surat held that delay in filing of an appeal before CIT(A) since the assessee was displaced from his office due to attachment of office on account of some purported fraud committed by him is sufficient cause.

Peak credit to be considered in case of circular transaction: ITAT Chennai

December 16, 2024 3606 Views 0 comment Print

ITAT Chennai held that only peak credit to be considered and no further addition to be made in case of circular transaction since bank account of appellant’s father duly considered for the purpose of calculating peak credit in the hands of assessee.

Matter remanded as due to death of assessee no one responded during assessment proceeding

December 16, 2024 1845 Views 0 comment Print

ITAT Jaipur remanded the matter back to the file of AO since ex-parte order was passed due to non-appearance/ non-furnishing of response since assessee died during pendency of the proceedings.

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