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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


Addition u/s. 68 matter send back for de novo proceedings due to unclear information: ITAT Bangalore

October 5, 2024 579 Views 0 comment Print

ITAT Bangalore held that addition under section 68 of the Income Tax Act towards unexplained money send back for de novo reassessment due to difference in amounts and unclear information.

Reopening u/s. 148 justified as full material was not available with AO at time of assessment: Delhi HC

October 5, 2024 573 Views 0 comment Print

The petitioner has filed the present petition impugning a notice dated 27.03.2018 issued under Section 148 of the Income Tax Act, 1961 for reopening the petitioner’s assessment for the Assessment Year 2011-12.

Income Tax Reassessment: Insights from SC Rulings in Ashish Agarwal & Rajeev Bansal

October 5, 2024 8457 Views 0 comment Print

Explore key insights on income tax reassessments in light of recent Supreme Court rulings, focusing on changes to procedures and time limits.

Mere Entering into Development Agreement doesn’t Allow Section 45(2) Invocation: ITAT Jaipur

October 4, 2024 1200 Views 0 comment Print

ITAT Jaipur held that mere entering into the Development Agreement would not permit invocation of section 45(2) of the Income Tax Act. There is no positive act which indicates that the assessee has treated capital asset as stock-in-trade.

Reopening of assessment u/s. 148 after due application of mind justifiable: ITAT Chennai

October 4, 2024 822 Views 0 comment Print

ITAT Chennai held that approval of large number of cases in a single day cannot be reason for faulting reopening of assessment since the case was reopened u/s. 148 of the Income Tax Act after due application of mind.

Landmark SC Judgment on TOLA & for 90000 Income Tax Reassessment cases

October 4, 2024 14559 Views 0 comment Print

SC clarifies TOLA’s application to Income Tax Act post-April 2021, covering reassessment notice deadlines and procedural timelines. Notices beyond limits are void.

Granting opportunity to cross examine essential as addition based on 3rd party statement: ITAT Bangalore

October 2, 2024 1128 Views 0 comment Print

ITAT Bangalore held that granting an opportunity to cross examine essential when addition is made on the basis of 3rd party statements. Non-granting any opportunity of cross examination violates the principle of natural which vitiates the validity of addition.

Non-compliance of notice due to COVID-19 restriction doesn’t attract penalty u/s. 272A(1)(d): ITAT Pune

October 1, 2024 1146 Views 0 comment Print

The Revenue’s action in mulcting the penalty by asking the assessee to prove the reasonable cause [COVID- 19] with documentary evidence capable of suggesting non-application of mind by the tax authorities.

Issuance of notice by Jurisdictional Officer invalid in view of provisions of section 151A: Himachal Pradesh HC

October 1, 2024 1305 Views 0 comment Print

Himachal Pradesh High Court held that in view of the provisions of Section 151A of the Income Tax Act read with the Scheme dated 29th March, 2022 the notices issued by the Jurisdictional Assessing Officers and not in prescribed faceless manner are invalid and bad in law.

Reassessment Invalid Due to Six-Day Notice Period Under Section 148A(b) Instead of Required 7 Days

September 30, 2024 1350 Views 0 comment Print

Reassessment notice issued to assessee by AO was quashed due to non-compliance with the statutory requirement of providing a minimum of seven days for the taxpayer to furnish a reply under Section 148A(b).

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