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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 114 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


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

July 17, 2024 1512 Views 0 comment Print

Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST by suppliers can’t justify reopening an assessment after 4 years.

Section 153A: No Additions Without Incriminating Material for Completed Assessments

July 16, 2024 1074 Views 0 comment Print

Delhi High Court dismisses Income Tax Department’s appeal in PCIT Vs Satya Prakash Gupta case, finding no evidence of commission receipt from foreign entities. Read the detailed judgment and analysis.

ITAT Can Holistically Evaluate Disclosures and Make Additions to Taxpayers’ Declared Income

July 16, 2024 543 Views 0 comment Print

Income Tax Settlement Commission (ITSC) had authority to make additions to the declared income of taxpayers as ITSC’s role was not confined to regular assessments but extended to holistic evaluations of the disclosures and additional income brought to its notice through settlement proceedings.

Finalized Assessment Cannot Be Reopened for Property Deed Re-registration

July 16, 2024 912 Views 0 comment Print

Once an assessment has been finalized for a particular year, reassessment cannot be justified merely due to subsequent procedural events like re-registration of property deeds.

No issuance of reopening notice on mere suspicion of Bogus Unsecured Loan: ITAT Kolkata

July 16, 2024 1140 Views 0 comment Print

Read the full text of the ITAT Kolkata order in Keshav Shroff Vs ITO (AY 2016-17). Analysis shows why mere suspicion isn’t enough for an IT notice.

Insight Portal Data Valid for Reopening Tax Assessments: Rajasthan HC

July 15, 2024 1332 Views 0 comment Print

Rajasthan HC rules that using the Insight Portal for reopening income tax assessments under Section 148 is valid. Learn about Chaturbhuj Gattani vs. ITO case details.

ITAT upholds enhancement by CIT(A) as addition were based on facts & not mere suspicion

July 14, 2024 936 Views 0 comment Print

ITAT noted that CIT(A)’s decision was reasoned, considering discrepancies in repayment timelines and absence of proper documentation or corroborative evidence. It concluded that CIT(A)’s findings were based on facts and did not merely rely on suspicion.

Cash Deposits During Demonetization Don’t Automatically Taint Assessee

July 14, 2024 2136 Views 0 comment Print

Merely because certain cash was deposited in the specified bank notes by the assessee during the demonetization period will not make the assessee tainted party when the very same transaction are being made by the assessee in the part as well as in the future.

ITAT Deletes Additions for Unexplained Cash Deposits Based on Submitted Evidence

July 14, 2024 909 Views 0 comment Print

Detailed analysis of Dhoom Singh Sharma Vs ITO case where ITAT Delhi accepts agricultural income proof, overturning Rs.16.4 Lakhs addition. Read the full order.

Revenue Cannot Use Reassessment Powers as a Review Mechanism

July 10, 2024 1551 Views 0 comment Print

It is trite that under guise of power vested in Revenue to reassess an income which had escaped assessment upon production of fresh tangible material, it cannot be allowed to exercise power of review.

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