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Section 147

Latest Articles


Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 6573 Views 0 comment Print

Recent Judgements of Supreme Court on Income Tax Issues

Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....

January 22, 2024 8358 Views 1 comment Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...

December 10, 2023 19590 Views 7 comments Print


Latest News


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 6936 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 12900 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 41382 Views 2 comments Print

Notices for assessment/reassessment of income of old cases

Income Tax : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...

August 3, 2018 1893 Views 0 comment Print

No Reopening of Assessment to be made on Audit Objections: Committee Recommends

Income Tax : One of the key sources of dispute is the existing arrangement for follow up on audit objections by Internal Audit Party and the Re...

January 20, 2016 6657 Views 0 comment Print


Latest Judiciary


Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 66 Views 0 comment Print

Reassessment cannot be based solely on reevaluating existing facts without new substantive material

Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...

July 17, 2024 60 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 126 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 261 Views 0 comment Print

Non-Filing of GST Return by Supplier – Assessment Reopening Validity- ITAT Mumbai Order

Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...

July 17, 2024 744 Views 0 comment Print


Latest Notifications


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 8571 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 3063 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 5337 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 2934 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 14292 Views 1 comment Print


Hyper-technical view cannot be the basis to assume revisionary jurisdiction

December 11, 2023 693 Views 0 comment Print

ITAT Delhi while quashing the revisionary order passed by the Ld. Pr.CIT held that, mere non-deposit in the capital gains scheme account cannot be the basis to deny deduction u/s 54/54F when the LTCG amount had duly been reinvested within the time allowed under 54(1) and that a hyper-technical/perfectionists point of view cannot the basis to assume revisionary jurisdiction.  

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

December 10, 2023 19590 Views 7 comments Print

Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the procedure and legal rules applicable.

No Violation of Natural Justice Found as Petitioner Opts Not to Respond to Notices: Kerala HC

December 10, 2023 339 Views 0 comment Print

The court concluded that there was no violation of natural justice, especially as the petitioner chose not to respond to any notices. The assessment order was deemed valid, and the writ petition was dismissed, with the petitioner retaining the right to explore other legal remedies available.

Delay in filing appeal before Commissioner condoned on account of reasonable cause shown

December 7, 2023 1692 Views 0 comment Print

ITAT Mumbai held that delay of 33 months in filing appeal before Commissioner condoned on account of reasonable cause and outbreak of Covid-19. However, an amount of Rs. 51,000 directed to be deposited in the Prime Minister’s National Relief Fund (PMNRF).

Investment beyond six months in NABARD Bonds cannot be considered for claiming exemption u/s. 54EC

December 4, 2023 555 Views 0 comment Print

ITAT Mumbai held that investment in NABARD Bonds beyond the specified time of six months cannot be considered for claiming exemption under the provisions of section 54EC of the Income Tax Act.

Reopening of assessment u/s 148 unjustified as all material facts fully disclosed

December 4, 2023 1341 Views 0 comment Print

Madras High Court held that reopening of assessment u/s 148 of the Income Tax Act beyond the period of four years unjustified as all the particulars with regard to sale of agricultural land was disclosed before AO in full extent.

HC set aside Assessment order passed on Transferor/Non-existing Company 

November 30, 2023 321 Views 0 comment Print

Learn how the Madras High Court set aside an Assessment Order dated 09.03.2022 under Section 147 r/w Section 144 of the Income Tax Act, 1961 for the Assessment Year 2013-14 for Shapoorji Pallonji Samalpatti Operator Services Pvt Ltd

Delhi HC Stays alleged Time Barred Section 148 Income Tax Notice

November 30, 2023 2412 Views 0 comment Print

Delhi HC grants stay on alleged time-barred Section 148 Income Tax notice for AY 2012-13. Get insights into legal aspects and implications of decision.

AO not entitled to commence proceedings for reassessment based on change of opinion

November 28, 2023 642 Views 0 comment Print

Bombay High Court held that AO is not entitled to commence proceedings for reassessment under section 147 of the Income Tax Act based on change of opinion as material facts are fully and truly disclosed.

Initiation of proceedings against person other than searched person u/s 148 instead of 153C unsustainable

November 28, 2023 1830 Views 0 comment Print

ITAT Bangalore held that initiation of proceedings against the person other than the searched person under section 148, instead of section 153C, of the Income Tax Act is without any jurisdiction and hence held liable to be set aside.

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