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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


Reopening Invalid: Sec 148 Notice Before Sec 151 Approval Communication – Jurisdictional Defect Fatal – ITAT Kolkata

February 21, 2026 411 Views 0 comment Print

The Tribunal ruled that reopening of assessment is void where the notice under Section 148 was issued prior to communication of sanction under Section 151. Such procedural lapse renders the entire reassessment null and void.

Borrowed Satisfaction and Mechanical U/s 151 Approval Invalidate 147 Reopening – ITAT Kolkata

February 21, 2026 411 Views 0 comment Print

TAT Kolkata ruled that reopening based on unverified foreign information amounted to borrowed satisfaction. Since the sanctioning authority granted approval mechanically, the reassessment was declared void.

Delhi HC Dismisses Reopening Based Solely on Audit Objection

February 20, 2026 627 Views 0 comment Print

elying on Supreme Court precedent, the Court upheld ITAT’s finding that reopening based on reappraisal of existing records is invalid. The Revenue’s appeal was dismissed.

ITAT Bangalore: Cost of Construction Cannot Be Fully Disallowed; Matter Remanded to AO for Fresh Verification & Valuation

February 20, 2026 543 Views 0 comment Print

The ITAT Bangalore held that the entire cost of construction claimed by the assessee while computing capital gains on sale of property could not be outrightly disallowed merely due to lack of complete supporting documents.

ITAT Bangalore Quashes Reopening Based on Wrong Bogus LTCG Assumption; Deletes Double Addition U/s 68

February 20, 2026 330 Views 0 comment Print

The ITAT Bangalore held that reopening of assessment was invalid as it was based on an incorrect assumption that the assessee had claimed bogus long-term capital gains (LTCG) from penny stock transactions.

ITAT Quashes ₹11.23 Cr Reassessment as Section 148 Notice Held Time-Barred

February 20, 2026 639 Views 0 comment Print

The Tribunal held that the reassessment notice issued after the extended limitation period was invalid under Section 149. As a result, the entire reassessment based on alleged accommodation entries was quashed as void ab initio.

ITAT Restores Appeal After Wrongful Dismissal for Non-Payment of Advance Tax

February 20, 2026 405 Views 0 comment Print

The Tribunal held that Section 249(4)(b) does not apply in reassessment where no advance tax liability existed, setting aside dismissal of appeal and restoring it for decision on merits.

Reassessment Quashed as Year of Search Cannot Be Reopened Under Section 148

February 19, 2026 621 Views 0 comment Print

The Tribunal held that reassessment under Sections 147/148 is invalid when the assessment year is the year of search. Such cases must proceed under normal assessment provisions.

Bombay HC Quashes Reassessment as Section 148 Notice Issued by Wrong Authority

February 19, 2026 1014 Views 0 comment Print

The Court held that issuance of notice under Section 148 by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer is a jurisdictional defect. All consequential reassessment proceedings were set aside.

Mere Third-Party Excel Sheet Insufficient for Section 69 Addition: ITAT Chandigarh

February 19, 2026 5316 Views 0 comment Print

The alleged unexplained investment was based only on third-party statements and seized digital data. In absence of receipts, confirmations, or admission by the assessee, the addition of ₹50 lakh was deleted.

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