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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 2841 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 69 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 96 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 447 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


Reassessment Quashed: Sec 143(2) Notice Mandatory in 147 Cases; Return Filed Within TOLA Time Valid – ITAT Kolkata

February 21, 2026 513 Views 0 comment Print

The Tribunal ruled that failure to issue notice under Section 143(2) after receiving return in reassessment proceedings is a jurisdictional defect. The reassessment order was quashed.

Reassessment Beyond 3 Years Void for PCIT Approval Instead of PCCIT – ITAT Mumbai

February 21, 2026 351 Views 0 comment Print

ITAT Mumbai quashed reassessment beyond 3 years as approval under Sec 151(ii) was granted by PCIT instead of PCCIT/CCIT, rendering notice u/s 148 and entire proceedings invalid.

Sec 68 Addition on Share Capital & Premium Deleted: No AO Enquiry; High Premium Not Enough – ITAT Kolkata

February 21, 2026 3933 Views 0 comment Print

ITAT ruled that issuance of shares at premium does not automatically attract addition under Section 68. Proper documentation and lack of enquiry by the AO led to deletion of the addition.

Non-Application of Mind and Wrong AY Render Sec 147 Reopening Void – ITAT Kolkata

February 21, 2026 342 Views 0 comment Print

The Tribunal found repeated factual errors in recorded reasons and notices. As the reopening lacked live nexus with escapement of income, it was struck down as a nullity.

Penalty U/s 271D & 271E Deleted – Partner Capital Cash Not Covered U/s 269SS/269T: ITAT Kolkata

February 21, 2026 2355 Views 0 comment Print

The ITAT Kolkata held that cash introduced by partners as capital contribution in an LLP does not attract Section 269SS and therefore penalty under Section 271D was invalid.

Sec 69 Addition Deleted – NRI Property Funded by Overseas Remittances via Mother’s Bank Trail – ITAT Mumbai

February 21, 2026 414 Views 0 comment Print

The ITAT Mumbai deleted the ₹14.70 lakh addition made under Section 69, holding that the NRI assessee had adequately explained the source of investment in property through documented overseas remittances routed partly via his mothers bank account.

Reopening Quashed: Mechanical Sec 151 Approval Invalid; Rubber-Stamp Sanction Cannot Sustain Sec 147 – ITAT Kolkata

February 21, 2026 342 Views 0 comment Print

ITAT held that mere signature or rubber-stamp approval under Section 151 is invalid if it does not reflect independent satisfaction. The reassessment and consequent additions were quashed for lack of valid jurisdiction.

Bogus Purchase Addition Restricted to 5% as Sales Accepted & Banking Trail Proven: ITAT Mumbai

February 21, 2026 1374 Views 0 comment Print

ITAT Mumbai held 100% bogus purchase disallowance unsustainable where sales and banking trail were proven; restricted addition to 5% profit element, following earlier years.

NFAC Reassessment Void Without Sec 151A Notice – Assessment & 271(1)(c) Penalty Deleted – ITAT Kolkata

February 21, 2026 327 Views 0 comment Print

ITAT held that reassessment proceedings initiated by NFAC before Notification No. 18/2022 dated 29.03.2022 were without jurisdiction. Since Section 151A became effective only upon notification, the entire reassessment and related penalty were quashed.

Section 68 Addition Deleted for Want of Cross-Examination; Three Ingredients Proved – ITAT Kolkata

February 21, 2026 420 Views 0 comment Print

The Tribunal reaffirmed that providing PAN, confirmations, bank statements, and financial records satisfies statutory requirements. With no defects found by the AO, the addition was rightly deleted.

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