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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 75 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 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 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 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 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


Section 69 Property Addition Deleted – Agreement vs Sale Deed Difference Not Sufficient Evidence: ITAT Ahmedabad

February 24, 2026 360 Views 0 comment Print

The Tribunal upheld deletion of addition made on alleged unexplained investment in property. It held that difference between initial agreement value and final sale deed, without evidence of extra payment, cannot justify addition under Section 69.

₹1 Cr Penny Stock Addition u/s 69A Deleted – Reopening Based on Borrowed Satisfaction & No Assessee-Specific Evidence: ITAT Ahmedabad

February 24, 2026 378 Views 0 comment Print

The Tribunal ruled that invoking clause (i) instead of clauses (iii)/(iv) of Explanation 2 was legally incorrect where material belonged to another person. The reassessment proceedings were quashed for non-compliance with statutory procedure.

ITAT Chandigarh Quashes Reassessment Beyond 3 Years for Lack of Proper Section 151(ii) Sanction

February 24, 2026 555 Views 0 comment Print

The Tribunal held reassessment invalid as approval was taken from Pr. CIT instead of Pr. CCIT under Section 151(ii). Jurisdictional non-compliance rendered the notice void.

No Addition U/s 68 in Search Cases Without Incriminating Material – Penny Stock LTCG Additions Deleted – Dept Appeals Dismissed

February 24, 2026 321 Views 0 comment Print

ITAT Lucknow held that additions under Section 68 in search cases cannot be made without incriminating material found during search. Penny stock LTCG additions were deleted and departmental appeals dismissed.

ITAT Lucknow Quashes U/s 148 Reopening; U/s 148A(d) Order Passed Before Reply Time & Without Considering Assessee’s Response

February 24, 2026 312 Views 0 comment Print

ITAT Lucknow held that revision under Section 263 cannot be invoked without specifying what enquiries the AO failed to conduct. As the PCIT did not spell out such deficiencies, the revision order was quashed.

CIT(A) Cannot Dismiss Appeal for Non-Payment of Advance Tax in Reassessment: ITAT Indore

February 23, 2026 834 Views 0 comment Print

ITAT Indore held that Section 249(4)(b) does not apply in reassessment proceedings where no advance tax obligation arises. The dismissal of appeal without examining merits was set aside and the matter remanded for fresh adjudication.

Section 50C Inapplicable Where Property Rights Relinquished Earlier by Registered Agreement

February 23, 2026 633 Views 0 comment Print

The Tribunal held that transfer took place in 2000 upon execution of a registered development agreement and receipt of full consideration, not in 2008 when the sale deed was executed.

ITAT Rajkot Quashes Reassessment as Section 148 Notice Issued Beyond Surviving Time

February 23, 2026 477 Views 0 comment Print

The Tribunal held that the reassessment notice was time-barred under the Supreme Court ruling on surviving period. Notices issued beyond the permissible limit were declared invalid.

Section 68 Addition Deleted as Cooperative Society Accepted Deposits from Its Own Members

February 23, 2026 369 Views 0 comment Print

The Tribunal held that deposits received from members of a registered cooperative society cannot be treated as unexplained credits when supported by books and member-wise records.

Nothing indicated knowingly participation in sham transaction: Reopening quashed

February 23, 2026 303 Views 0 comment Print

Gujarat High Court held that the respondent officer could not have assumed jurisdiction for reopening the assessment since there was nothing which indicate that petitioner has participated knowingly in the sham transaction. Accordingly, order is quashed and set aside.

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