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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 5661 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1656 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 909 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2490 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...

March 9, 2025 66 Views 0 comment Print

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....

March 9, 2025 69 Views 0 comment Print

ITAT Surat Directs Re-examination of Tax on Gift from HUF

Income Tax : ITAT Surat remands case to CIT(A) for fresh adjudication on HUF gift taxability under Section 56(2)(vii) of the Income Tax Act, ci...

March 9, 2025 171 Views 0 comment Print

Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 240 Views 0 comment Print

Retrospective Amendment Doesn’t Justify Reassessment Beyond Four Years

Income Tax : Bombay High Court sets aside IT reassessment against Oxford University Press, ruling no failure to disclose material facts for reo...

March 8, 2025 153 Views 0 comment Print


Latest Notifications


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 246 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 9252 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 4092 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 5511 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 3021 Views 0 comment Print


No section 68 addition merely for trading in penny stock: ITAT Mumbai

December 2, 2024 5439 Views 0 comment Print

ITAT Mumbai upholds deletion of additions u/s 68 for trading in penny stocks. Assessee provided valid evidence, and AO failed to counter claims with proof.

Central Government Rescinds 6 Central Excise Notifications issued in 2022

December 2, 2024 246 Views 0 comment Print

Notification No. 29/2024-Central Excise rescinds six 2022 excise notifications in the public interest, effective immediately. Details on affected notifications inside.

Reassessment order quashed as mandatory requirement of notice u/s. 143(2) not complied

November 30, 2024 1353 Views 0 comment Print

ITAT Chandigarh held that reassessment order under section 147 of the Income Tax Act cannot be passed without compliance with mandatory requirement of notice under section 143(2) of the Income Tax Act. Thus, order passed u/s. 144 r/w 147 set aside.

Reassessment quashed as reasons supplied to assessee & to higher forum were not same

November 29, 2024 2853 Views 0 comment Print

ITAT Bangalore held that when the reasons supplied to the assessee and the reasons supplied before higher forum is not verbatim same, it cannot sustain the validity of reopening of assessment under section 147 of the Income Tax Act.

Addition u/s. 69 on protective basis not justified as genuineness of transaction established

November 29, 2024 765 Views 0 comment Print

ITAT Delhi held that addition under section 69 of the Income Tax Act on protective basis not justified since assessee established genuineness of transaction and creditworthiness of entity from which share application money is received.

PCIT expressing different view by invoking section 263 not justified: ITAT Ahmedabad

November 28, 2024 852 Views 0 comment Print

The assessment order u/s. 143(3) of the Act was passed on 03-07-2015 determining total income of Rs. 11,70,590/-. Thereafter, reassessment proceedings initiated and order u/s. 147 r.w.s. 144B was passed on 28-03­2022 by accepting the returned income.

Unexplained Investment & Loss Set-Off Case Remanded to AO for Lack of Details

November 26, 2024 312 Views 0 comment Print

The assessee has not filed any return of income. As per the information, the reasons were recorded and subsequently the case was reopened u/s. 147 of the Income Tax Act. In response to the notice u/s. 148 of the Act, the assessee did not file any reply.

Reassessment notice u/s. 148 being barred by limitation is liable to be quashed: ITAT Mumbai

November 26, 2024 8928 Views 0 comment Print

The present appeal is preferred by the revenue challenging quashing of the notice u/s. 148 of the Income Tax Act. Revenue has mainly contested that CIT (A) has quashed the notices on the ground that it is barred by limitation.

Addition u/s. 69A sustained since assessee remained non-compliant: ITAT Ahmedabad

November 26, 2024 1377 Views 0 comment Print

During the course of assessment proceedings, AO noticed that there was cash deposit of Rs. 36,48,000/- and credit entries of Rs. 21,93,269/-. AO observed that inspite of repeated reminders, assessee failed to submit the reply.

NFAC and Jurisdictional Assessing Officer hold concurrent jurisdiction: Delhi HC

November 25, 2024 3300 Views 0 comment Print

In Sanjay Gandhi Memorial Trust v. Commissioner of Income Tax (Exemption), the Court concluded that, while the faceless system centralizes case handling through the NFAC, this framework does not completely replace or nullify the JAO‘s role.

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