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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 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


Reopening of assessment based on wrong facts liable to be quashed: ITAT Mumbai

October 29, 2024 2064 Views 0 comment Print

ITAT Mumbai held that once the issue of reopening was examined in the scrutiny assessment proceedings, the reason framed under wrong facts are not valid reason, therefore such reasons to believe cannot be sustained. Thus, reopening of assessment quashed.

Section 143(1) is not considered an assessment by the AO for purposes of Section 147

October 28, 2024 5925 Views 0 comment Print

Delhi High Court held that the assessment of tax under Section 143(1) of the Income Tax Act is a self-assessment and in a strict sense cannot be stated as assessment framed by the AO for the purpose of reopening of assessment under section 147.

Addition untenable as decentralized grants routed through assessee is not actually accrued or arisen

October 28, 2024 600 Views 0 comment Print

ITAT Ahmedabad held that taxation must be based on income that has actually accrued or arisen. Thus, addition towards decentralized grants merely routed assessee and simply transferred to other government agencies as per GOG’s directions is unsustainable.

ITAT sets aside Ex-Parte Addition Due to Assessee’s Illness, Husband’s Death; Remands Case to CIT(A)

October 27, 2024 759 Views 0 comment Print

ITAT Chandigarh sets aside ₹29.5 lakh addition against Bachan Kaur, allowing a fresh hearing due to her illness and husband’s death.

Section 115JB Inapplicable to corresponding new bank: ITAT Bangalore

October 26, 2024 564 Views 0 comment Print

The fiction created by Section 11 of the Acquisition Act, does not imply that the assessee bank would also become a company for the purpose of the Companies Act for which Clause (b) of Sub-Section 2 of Section 115JB is applicable.

Completion of revisionary proceeding within short span of 12 days unjustified: Matter restored back

October 25, 2024 576 Views 0 comment Print

ITAT Ahmedabad held that the entire proceedings under Section 263 of the Act were initiated and completed by the PCIT within a period of only 12 days without pointing out reason for lack of enquiry unjustified. Accordingly, matter restored back.

Provisions of 68 are not applicable on the sale transactions which is already credited in P&L: ITAT Jaipur

October 23, 2024 1605 Views 0 comment Print

ITAT Jaipur held that provisions of 68 as such are not applicable on the sale transactions recorded in the books of accounts because the sale transaction are already part of the income which is already credited in statement of profit & loss account.

No reassessment on basis of invalid notice u/s 148, deleted additions of 6.93 Crores

October 23, 2024 2553 Views 0 comment Print

Reassessment initiated under an invalid notice issued under Section 148 as there was no new material with AO after four years that the assessee had escaped assessment, therefore, additions amounting to ₹6.93 crores was deleted.

Reassessment u/s. 147 not justified as reasons recorded is plagued with several defects: ITAT Delhi

October 22, 2024 825 Views 0 comment Print

ITAT Delhi held that reasons recorded for exercising the jurisdiction is plagued with several defects of critical nature. Thus, due to lack of jurisdiction u/s. 147 of the Income Tax Act reassessment proceedings held as bad-in-law.

CIT(A) Must Provide Reasoned Order and Fair Hearing: ITAT Jaipur

October 22, 2024 858 Views 0 comment Print

ITAT Jaipur reviews Vimla Devi Agrotech Ltd.’s penalty appeal for non-maintenance of accounts under section 271B of the IT Act, highlighting procedural errors.

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