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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 69 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


₹14 Lakh Unexplained Investment Addition Reopened Due to Incomplete Evidence Review

February 27, 2026 276 Views 0 comment Print

The Tribunal remanded the reassessment after the assessee sought another opportunity to explain the source of investment. The addition was set aside subject to payment of costs and fresh adjudication on merits.

LTCG Addition Deleted as AO Failed to Prove Share Transactions Bogus Under Section 68

February 26, 2026 432 Views 0 comment Print

ITAT Mumbai deleted the Section 68 addition on LTCG from listed shares, holding that documentary evidence, STT payment, and banking trail were not disproved by the Revenue.

Reassessment Upheld as Section 148 Notice Issued Within Limitation Despite clerical error in email attachment

February 26, 2026 495 Views 0 comment Print

The Delhi High Court held that issuance of notice within limitation is sufficient, and an inadvertent attachment of another assessee’s document is a curable defect, not a jurisdictional flaw.

Reassessment Quashed as Escaped Income Below ₹50 Lakh Threshold: ITAT Mumbai

February 25, 2026 636 Views 0 comment Print

The Tribunal held that reopening beyond three years was invalid since the alleged escaped income, after considering bank loan evidence, was below ₹50 lakh. The notice under section 148 and final assessment were quashed as time-barred.

No Section 263 Revision When Two Views Possible on Section 28 Interest on Enhanced Compensation

February 25, 2026 375 Views 0 comment Print

The Tribunal held that where the AO had examined and accepted exemption on interest under Section 28 of the Land Acquisition Act, revision under Section 263 was not justified.

FMV of flat received on surrender of tenancy right will be cost of acquisition

February 25, 2026 522 Views 0 comment Print

ITAT Mumbai held that the cost of acquisition in present case would be the FMV of the flats which the assessee has acquired in exchange of surrender of tenancy right to the developer. Accordingly, AO is directed to re-compute cost of acquisition.

Post search abatement of pending assessments under 158BA(2) is not automatic

February 24, 2026 393 Views 0 comment Print

Orissa High Court held that post search operation all pending assessments/reassessments doesn’t not automatically get abated as provisions of section 158BA(2) of the Income Tax Act. Matter must specifically fall within Block Assessment Scheme for abatement. However, writ dismissed as power under Article 226 not invoked.

Section 11(3) Addition Partly Upheld: ₹1.24 Cr (AY 1994-95) Survives; Earlier Accumulations Nil; Matter Remanded to CIT(A) – ITAT Hyderabad

February 24, 2026 252 Views 0 comment Print

ITAT Hyderabad held only ₹1.24 crore accumulation from A.Y. 1994-95 survives for possible Section 11(3) taxation; earlier years’ accumulations were non-existent, and matter restored to CIT(A) for limited verification.

ITAT Hyderabad Quashes U/s 148 Reopening; Third-Party Seized Laptop Data & Non-Compliance with Sec 149(1)(b) Held Fatal

February 24, 2026 531 Views 0 comment Print

The Tribunal quashed the reassessment as the notice issued beyond three years failed to satisfy mandatory conditions under Section 149(1)(b). It held that absence of proper jurisdictional facts and compliance rendered the reopening invalid.

ITAT Mumbai Deletes Capital Gains Addition for Unsigned MOU & Cross-Examination Denial

February 24, 2026 336 Views 0 comment Print

The Tribunal set aside a capital gains addition based solely on an unsigned digital MOU found in a third-party survey. It held that denial of document copies and cross-examination vitiated the assessment for violating principles of natural justice.

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