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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


Advance tax payment provisions doesn’t apply to reassessment proceedings: ITAT Indore

August 17, 2024 1065 Views 0 comment Print

ITAT Indore held that rejection of appeal by CIT(A) on the footing of non-payment of advance tax as required by section 249(4)(b) untenable as payment of advance tax is not applicable in case of reassessment proceedings.

Section 148 notice to NRI Without Mandatory Faceless Procedure Unsustainable: Telangana HC

August 17, 2024 2505 Views 0 comment Print

Telangana High Court held that notice issued u/s. 148 of the Income Tax Act must comply with the requirement of the Scheme whether or not the Taxpayer is NRI/Indian Citizen. Thus, issuance of notice to NRI u/s. 148 without following mandatory faceless procedure is set aside.

Bogus purchase addition cannot be based on superficial inquiry: Bombay HC

August 17, 2024 3249 Views 0 comment Print

Bombay High Court held that half-hearted approach on the part of AO to make additions on the issue of bogus purchase would not be conducive. Bogus purchase addition also cannot be on the basis of superficial inquiry.

Notice u/s. 148A issued by Jurisdictional AO instead of Faceless AO liable to be quashed: Bombay HC

August 17, 2024 6294 Views 0 comment Print

Bombay High Court held that issuance of notice under section 148A of the Income Tax Act by Jurisdictional Assessing Officer and not by a Faceless Assessing Officer as required by the provisions of section 151A of the Income Tax Act is liable to be quashed.

CIT needs to independently apply his mind prior to invoking revisionary provisions u/s. 263: ITAT Kolkata

August 16, 2024 552 Views 0 comment Print

ITAT Kolkata held that CIT has not applied his mind analytically while assuming jurisdiction for taking cognizance under section 263 of the Income Tax Act. Thus, in absence of independent application of mind, invocation of revisionary provisions by CIT unsustainable.

Passing of revisionary order u/s. 263 without giving adequate opportunity of being heard unsustainable: ITAT Ahmedabad

August 15, 2024 795 Views 0 comment Print

ITAT Ahmedabad held that passing of revisionary order by PCIT u/s. 263 of the Income Tax Act without giving proper and adequate opportunity of being heard to the assessee is liable to be set aside.

Dismissal of appeal for non-payment of self-assessment tax unjustified as no tax was payable due to losses: ITAT Hyderabad

August 13, 2024 714 Views 0 comment Print

ITAT Hyderabad held that dismissal of appeal by CIT(A) on the ground of non-deposition of self-assessment tax by the assessee needs re-verification since assessee incurred losses and therefore has a reason for not depositing the self-assessment tax. Hence, matter remanded.

Revision u/s. 263 set aside as order of AO not found to be erroneous and prejudicial to interest of revenue: ITAT Ahmedabad

August 13, 2024 486 Views 0 comment Print

ITAT Ahmedabad held that order of PCIT invoking section 263 of the Income Tax Act set aside as conditions necessary for invoking Section 263 of the Act, i.e., the order being erroneous and prejudicial to the interest of the revenue, are not satisfied.

Section 2(14): No capital gains tax on Income proceeds from Agricultural Land

August 13, 2024 1326 Views 0 comment Print

Notice under section 148 was issued upon assessee by AO for reassessing the cash deposit as undisclosed income, following approval from the Joint Commissioner of Income Tax (JCIT).

Addition merely based on retracted statement without any incriminating material unsustainable: ITAT Ahmedabad

August 12, 2024 909 Views 0 comment Print

ITAT Ahmedabad held that addition merely on the basis of retracted statement without any incriminating material seized from assessee’s premises is unsustainable in law and liable to be quashed.

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