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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


HC Quashes reassessment notice & order for absence of application of mind & errors in approval

February 21, 2024 4209 Views 0 comment Print

Bombay High Court quashes reassessment notice against Kartik Gandhi for AY 2019-20, highlighting issues with Section 148 and 151 approvals.

Source for making or earning income of payer of FTS outside India is not taxable in India

February 20, 2024 1899 Views 0 comment Print

ITAT Delhi held that as conditions prescribed in exception to section 9(1)(vii)(b) stand fulfilled, it cannot be taxed as FTS. Further, the source for making or earning any income of the payer of fee for technical services, in the present case, is outside India, and therefore not taxable in India.

Old provisions of section 148 including TOLA cannot be applied to new regime: Calcutta HC

February 20, 2024 4353 Views 0 comment Print

Calcutta High Court held that the provisions of old regime of Section 148 of the Income Tax Act (including TOLA) cannot be applied to new regime applicable from 01.04.2021. Accordingly, impugned notices quashed being barred by limitation.

Section 148 lacks allegations of non-disclosure; jurisdiction assumption U/s. 147 is invalid

February 20, 2024 720 Views 0 comment Print

Delhi High Court finds Section 148 notice flawed due to lack of non-disclosure allegations; declares Section 147 jurisdiction assumption invalid.

3-Year Limit for Tax Reassessment Notice if concealed income below 50 lakh: Jharkhand HC

February 19, 2024 3816 Views 0 comment Print

Explore the Jharkhand High Court judgment limiting tax reassessment period for concealed income below 50 lakh. Detailed analysis of Sevensea Vincom Pvt Ltd vs PCIT case.

No Tax on Salary for Non-Resident Assessee Rendering Services Outside India: ITAT

February 15, 2024 1632 Views 0 comment Print

Explore the ITAT Delhi ruling on Devi Dayal Vs DCIT regarding taxation of salary earned by a non-resident outside India. Detailed analysis and conclusion provided.

ITAT Confirms Reassessment & Section 68 Addition on Share Subscription

February 15, 2024 876 Views 1 comment Print

 ITAT Upholds Reassessment on Accommodation Entry Info from Investigation Wings & affirms Addition u/s 68 Due to Lack of Credibility Evidence in Share Subscription

Provisions of IBC overrides provisions of State enacted law: NCLT Hyderabad

February 15, 2024 588 Views 0 comment Print

NCLT Hyderabad held that the provisions of the Insolvency & Bankruptcy Code, 2016 (IBC) override the provisions of the State enacted law, such as, Andhra Pradesh Revenue Recovery Act, 1864.

ITAT: Sale of Shares Capital Gains Not Sham, Deletes Section 69A Additions

February 15, 2024 2067 Views 0 comment Print

Delhi ITAT’s landmark ruling in Sarika Bindal vs. ITO establishes that capital gains from share sales cannot be deemed sham, safeguarding taxpayer rights.

AO Cannot Reopen Assessment to Correct Oversight: Bombay HC

February 14, 2024 1017 Views 0 comment Print

Bombay High Court ruled AO can’t reopen assessment due to oversight. Emkay Global Financial Services Limited Vs ACIT details.

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