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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 18264 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 102 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


ITAT allows Expenditure on power of attorney, air tickets, hotel stays against capital gain

March 24, 2024 14019 Views 0 comment Print

In Adil Rehman’s case, ITAT Hyderabad allows expenditure on special power of attorney, air tickets, hotel stays, etc., as deductible in computing capital gains under Section 48(i) of the Income Tax Act.

India-Thailand DTAA: Non-Resident’s Fee for Technical Services Exempt from Taxation

March 24, 2024 4503 Views 0 comment Print

Discover the ITAT Delhi ruling on taxing income from providing business support services to Indian group entities. Analysis of Solvay Asia vs. DCIT case under India-Thailand DTAA.

Payment towards interconnect usage charges to foreign telecom operators not taxable in India: ITAT Mumbai

March 23, 2024 864 Views 0 comment Print

ITAT Mumbai held that the payment made towards interconnect usage charges to foreign telecom operators does not accrue or arise in India and in the absence of any permanent establishment in India could not be brought to tax in India under Article 7 of DTAA.

Allahabad HC Invalidates Notice u/s. 148A(b) for Service to Unregistered Email ID

March 23, 2024 4470 Views 0 comment Print

Allahabad High Court held that valid service of notice under section 148 of the Income Tax Act is a condition precedent for making reassessment under section 147. Accordingly, non-service of notice on registered email ID is unsustainable in the eyes of law.

Assessment framed Without Disposal of Assessee’s Objections is Invalid: ITAT Kolkata

March 23, 2024 1434 Views 0 comment Print

ITAT emphasized that the AO must decide on the objections raised by the assessee before proceeding with the assessment. Failure to do so renders the assessment bad in law.

Section 276CC Prosecution: Appellate Proceedings Irrelevant but Wilful Failure to Furnish Returns Must Exist

March 22, 2024 933 Views 0 comment Print

In Vinayagam Sabarisanthanakrishnan Vs ACIT, Madras HC clarifies that failure to file returns under Sec 139(1) is essential for prosecution under Sec 276CC of the Income Tax Act.

HC Quashes Reassessment Notice: Approval Granted Without Application of Mind

March 22, 2024 1104 Views 0 comment Print

Delhi High Court judgment in Sanjay Kumar Vs ACIT reveals flaws in reassessment proceedings, jurisdictional issues, and errors in income tax notice.

ITAT Deletes Cash Deposit Addition; Source Linked to Property Sale Advance received by father

March 21, 2024 855 Views 0 comment Print

In the case of Aashish Luthra vs. ITO, ITAT Mumbai deletes cash deposit addition after establishing the source as property sale advance received by the father.

Reopening of assessment u/s. 147 based on change of opinion is unsustainable-in-law: Bombay HC

March 21, 2024 1905 Views 0 comment Print

Bombay High Court held that reopening of assessment under section 147 of the Income Tax Act, without any fresh and tangible material, merely on the basis of change of opinion is unsustainable in law.

Receiving funds from a company alone doesn’t imply income evasion

March 21, 2024 750 Views 0 comment Print

The mere receipt of funds from M/s Solvent Real Estate Pvt. Ltd. did not constitute tangible evidence of income escapement by the assessee. Despite efforts by the assessee to provide explanations and evidence, the AO failed to conduct independent inquiries and relied solely on the information received.

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