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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


Assessee Not Penalized for CA’s Fault; 1430 Appeal Delay Condoned

July 22, 2024 1512 Views 0 comment Print

Read the full text of ITAT Ahmedabad’s order where the delay in filing an appeal by the assessee was condoned due to CA negligence. Details on the case and implications.

ITAT Directs Assessee to Prove Creditor’s Identity and Creditworthiness

July 19, 2024 633 Views 0 comment Print

Explore the detailed case of Sankpal Developers vs. ITO (ITAT Mumbai) regarding the treatment of unsecured loans under Section 68 of the Income Tax Act, 1961. Understand the implications of proving creditworthiness and genuineness in tax assessments.

Without incriminating material, additions cannot be made to completed/unabated assessments

July 19, 2024 1059 Views 0 comment Print

Detailed analysis of ACIT Vs Mansha Agencies Pvt Ltd (ITAT Mumbai) case where Mumbai ITAT rules that additions can’t be made in unabated assessments without incriminating material. Read the full text of the ITAT Mumbai order.

Reopening Based on Wrong Facts or assumptions is Invalid: ITAT Mumbai

July 19, 2024 1122 Views 0 comment Print

Read the full text of the ITAT Mumbai order in Laxman Gore Shreshtha Vs DCIT. Analysis of reassessment based on incorrect details and implications for assessment under Income Tax Act.

Section 56(2)(vii)(c) not applicable to bonus shares as no Transfer of Property

July 19, 2024 1800 Views 0 comment Print

Detailed analysis of DCIT vs Tangi Facility Solutions Pvt Ltd case by ITAT Chennai regarding taxation of bonus shares under Income Tax Act. Understand ITAT’s ruling and implications.

Reassessment cannot be based merely on suspicion or unverified information

July 18, 2024 1878 Views 0 comment Print

Read the full text of the ITAT Kolkata order on Alosha Marketing Pvt Ltd Vs ACIT, discussing reopening of assessment under sec 147 and challenges on merit.

Reopening Without New Material & on Mere Change of Opinion invalid

July 17, 2024 525 Views 0 comment Print

Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence supporting income escapement from stock trading.

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

July 17, 2024 471 Views 0 comment Print

PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of existing facts without new, substantive material indicating income escapement.

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

July 17, 2024 678 Views 0 comment Print

Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD and 80IA(4)(iv) during scrutiny assessment. Despite furnishing all details, AO issued a notice for reassessment, alleging income escapement related to the deduction under section 80IA.

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

July 17, 2024 717 Views 0 comment Print

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

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