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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 57 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 96 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 66 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 84 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


Due to short gap between three notices CIT(A) directed to give one more opportunity of being heard

September 2, 2024 366 Views 0 comment Print

ITAT Jaipur held that there was short gap between three notices issued as say the opportunities granted hence it a fit case were one more opportunity should be granted in the proceedings before CIT(A), to enable the assessee to represent his appeals.

No revisional jurisdiction u/s. 263 as issue examined during assessment proceeding: ITAT Ahmedabad

September 2, 2024 549 Views 0 comment Print

ITAT Ahmedabad held that revisional jurisdiction u/s. 263 of the Income Tax Act not justifiable as AO had examined the issue in the course of assessment proceeding.

Failure to conduct enquiry resulted into order being erroneous and prejudicial hence revision u/s. 263 sustained

August 31, 2024 801 Views 0 comment Print

ITAT Ahmedabad held that assessment order passed by AO without conducting adequate inquiry is erroneous and prejudicial to the interest of revenue and hence revisionary proceeding under section 263 rightly invoked by PCIT.

Proceedings u/s. 153C should be initiated based on material found at premises of another company

August 31, 2024 1332 Views 0 comment Print

ITAT Ahmedabad held that initiation of proceedings u/s. 147 of the Income Tax Act based on material found during search of another company is untenable as proceedings should be initiated u/s. 153C and not u/s. 147.

Settlement Commission Orders Not Rectifiable Under Section 154: Madras HC

August 31, 2024 483 Views 0 comment Print

Madras HC rules Settlement Commission orders can’t be rectified under Section 154 of the Income Tax Act, upholding the principles from Brij Lal case.

Reassessment after expiry of four years unsustainable as material fact disclosed fully: Bombay HC

August 31, 2024 1059 Views 0 comment Print

Bombay High Court held that initiation of reopening of assessment after expiry of four years from the end of relevant assessment year without failure on part of the petitioner to disclose any material fact fully and truly is unsustainable in law.

Normal period will apply for reopening of assessment where escapement of income is below 50 Lakhs

August 31, 2024 2457 Views 0 comment Print

ITAT Mumbai held that normal period of limitation i.e. 3 years will apply in case of reopening of assessment where escapement of income was below Rs. 50 Lakhs and extended period of 10 years will apply only in case of concealment of income of Rs. 50 Lakhs or more.

No re-assessment by AO u/s 147 in case of unprocessed original return

August 31, 2024 1209 Views 0 comment Print

Re-opening of assessment by AO was unjustified if the original return had not been processed by following the decision in case of Super Spinning Mills Ltd. vs Addl. CIT 37 DTR (Chennai) (T.M) (Trib).

No Physical Notice in Ex-Parte Proceedings – ITAT Remands Case to CIT(A)

August 29, 2024 3756 Views 0 comment Print

ITAT Delhi remands case to CIT(A) for fresh adjudication due to lack of physical notice before ex-parte decision on unexplained investment.

Addition u/s 68 was deleted as no incriminating material found during search for Unabated AY

August 29, 2024 1011 Views 0 comment Print

However, the completed/unabated assessments could be re-opened by the AO in exercise of powers under sections 147/148, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 and those powers were saved.

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