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Section 147

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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 63 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 105 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 96 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 90 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 Valid Where Loose Papers and Purchaser’s Statement Indicate On-Money: ITAT Ahmedabad

March 5, 2026 645 Views 0 comment Print

The ITAT relied on surrounding circumstances, documentary evidence, and the principle of human probabilities to conclude that cash consideration was paid in a land transaction. The Tribunal confirmed the addition of unaccounted sale consideration as short-term capital gains.

Faceless Reassessment Invalid Because Section 151A Scheme Was Not Yet Notified: ITAT Kolkata

March 4, 2026 2394 Views 0 comment Print

The Tribunal ruled that a reassessment order passed prior to notification of the faceless reassessment scheme under Section 151A was without jurisdiction. As the enabling notification came after the assessment date, the entire order was declared void.

Reassessment Notice Quashed as Issued Beyond Surviving Limitation Under TOLA and Section 149

March 2, 2026 1407 Views 0 comment Print

The High Court held that only 30 days of limitation survived after applying TOLA and Supreme Court rulings. Notices issued after expiry of the surviving period were declared time-barred.

Rs. 50 Lakh LIC Investment Treated as Unexplained Due to Failure to Prove HUF Source

March 2, 2026 747 Views 0 comment Print

The Tribunal upheld addition under Section 69 as the assessee failed to establish that the LIC investment belonged to the HUF. Mere assertion of agricultural income without documentary evidence was held insufficient.

Interest Under Section 28 of Land Acquisition Act Not Taxable as ‘Other Sources’: ITAT Delhi

March 2, 2026 936 Views 0 comment Print

ITAT Delhi held that interest awarded under Section 28 is an accretion to compensation and cannot be taxed as income from other sources. The appeal was allowed following Supreme Court precedent.

Excel Sheet Alone Not Sufficient Proof: ITAT Ahmedabad Deletes Cash Payment Addition

March 1, 2026 3135 Views 0 comment Print

ITAT Ahmedabad held that an unsigned Excel sheet found during survey, without corroborative evidence, cannot justify addition for alleged cash payments.

Reassessment Notice for AY 2015-16 Quashed as Time-Barred Under Section 149

March 1, 2026 3132 Views 0 comment Print

The Tribunal held that notices issued on or after 01.04.2021 for A.Y. 2015-16 were invalid in view of the Supreme Court’s ruling in Rajeev Bansal. As the reopening was barred by limitation, the reassessment order was quashed.

Reassessment u/s. 148 non-jurisdictional as revisionary proceeding u/s. 263 dropped on same issue

February 28, 2026 369 Views 0 comment Print

ITAT Delhi held that initiation of re-assessment proceedings under section 148 of the Income Tax Act is liable to be quashed as without jurisdiction since revisionary proceedings under section 263 on the same issue was already dropped.

Sections 147 & 148 of Income-Tax Act: Reassessment From ‘Reason to Believe’ to ‘Information’

February 28, 2026 873 Views 0 comment Print

A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods while strengthening natural justice safeguards.

Section 148 Notice Quashed for Mechanical Approval Without Recorded Satisfaction: Delhi HC

February 28, 2026 567 Views 0 comment Print

The Delhi High Court set aside reassessment proceedings after finding that the PCIT granted only a signature without recording satisfaction, violating the statutory requirement of prior approval.

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