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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 18261 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


Reopening of assessment based on wrong and irrelevant facts is unsustainable-in-law

October 19, 2023 8427 Views 0 comment Print

ITAT Chandigarh held that reopening of assessment under section 147 of the Income Tax Act based on wrong and irrelevant facts recorded under the reasons recorded for the formation of belief of escapement of income chargeable to income tax is unsustainable in law and liable to be quashed.

No addition on account of Royalty Income received by UK Telecom Company from Indian Telecom Company for rendering roaming services to customers abroad

October 19, 2023 456 Views 0 comment Print

Income received by assessee-UK telecom company from an Indian telecom company for rendering roaming services to customers abroad was not ‘royalty’ as assessee-UK had not provided any right, as mentioned in Explanation 2 to Section 9(1)(vi), or any kind of use of any process or equipment to VIL

Section 54F Deduction Granted: New House Purchase within Two Years of Asset Transfer

October 19, 2023 813 Views 0 comment Print

In a crucial ruling, ITAT Chennai allows Section 54F deduction for a new residential property purchase, clarifying tax implications. Learn more in this detailed analysis.

ITAT Hyderabad: Cash Deposit by NRI, Deletion of Addition

October 19, 2023 1089 Views 0 comment Print

In a case involving Smt. Madhuvalli Lakamraju vs. ADIT, ITAT Hyderabad deletes the addition under section 68 of the Income Tax Act due to lack of source for cash deposits.

Addition u/s. 69C treating share transactions as bogus only based on statement of broker unsustainable

October 19, 2023 1665 Views 0 comment Print

ITAT Mumbai held that addition under section 69C of the Income Tax Act treating share transactions as bogus merely on the basis of statement of the broker is unsustainable and bad-in-law.

Initiation of re-assessment based on material already on record is bad-in-law

October 16, 2023 2487 Views 0 comment Print

Madras High Court held that initiation of proceedings for reassessment under section 147 of the Income Tax Act based on material already on record and without new/ tangible information is bad-in-law and liable to be quashed.

Section 50C not apply to property purchased/ sold as business property

October 14, 2023 5187 Views 0 comment Print

ITAT Jaipur held that provisions of section 50C of the Income Tax Act is not applicable because the immovable property was purchased/ sold as business property. Further, profit earned was duly reflected in the return of income. Accordingly, demand set aside.

Revision order u/s 263 without satisfying two essential condition is unsustainable

October 14, 2023 687 Views 0 comment Print

ITAT Delhi held that invocation of revisionary power u/s 263 of the Income Tax Act without satisfying two conditions i.e. order was erroneous and it was prejudicial to the interest of revenue is unsustainable in law and liable to be quashed.

No assessment can be reopened merely on the basis of change of opinion

October 9, 2023 1845 Views 0 comment Print

Bombay High Court held that no assessment can be reopened merely on the basis of change of opinion. Accordingly, initiation of re-assessment proceedings under section 148 of the Income Tax Act is unsustainable in law.

Mechanical issuance of notice u/s 148 of the Income Tax Act is unsustainable

October 7, 2023 1551 Views 0 comment Print

ITAT Chennai held that notice u/s 148 of the Income Tax Act being issued mechanically by AO without going through the original assessment records and without verification of documents on records is unsustainable in law.

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