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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 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


Section 270A Penalty is not automatic & necessitate a substantial misrepresentation or suppression of facts

September 2, 2023 3945 Views 0 comment Print

ITAT Chennai rules in the case of Kannappan Vijayalakshmi vs ITO, stating that the mere non-acceptance of a claim by the assessee doesn’t mean automatic penalty under section 270A(9)(a). Explore the detailed analysis and implications.

Non-Cooperation by Tax Consultant: ITAT Orders Fresh Adjudication

September 2, 2023 1932 Views 0 comment Print

Read how ITAT Ahmedabad orders fresh adjudication due to non-cooperation of tax consultant in furnishing property investment details in Pravinchandra Naranbhai Patel case.

Addition u/s 68 merely based on suspicion unsustainable

September 1, 2023 2163 Views 1 comment Print

ITAT Mumbai held that addition under section 68 of the Income Tax Act towards unexplained expenditure merely on the basis of suspicion without any other support is unsustainable in law.

ITAT deletes addition for duly explained cash deposit

September 1, 2023 1038 Views 0 comment Print

Review of ITAT Mumbai’s ruling in Kamlesh Vasant Nerkar Vs CIT, emphasizing the need for AO to recognize income that has been adequately explained by the taxpayer.

Share Premium not taxable in the hands of investee if Investor already taxed for it

September 1, 2023 768 Views 0 comment Print

Analysis of ITAT Chennai’s decision on taxing share premium: ACIT Vs Luncar Finance Pvt. Ltd. A focus on already taxed income in the hands of Investor Company

Payments towards Interconnectivity Utility Charges not royalty/ FTS hence not taxable

August 31, 2023 816 Views 0 comment Print

ITAT Bangalore held that payments received by assessee towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty / FTS to be brought to tax in India under section 9(1)(vi)/(vii) of the Act and also as per DTAA.

Addition based on claim of payment of cash in civil suit sustained as source of cash payment not explained

August 31, 2023 1266 Views 0 comment Print

ITAT Mumbai held that addition towards unexplained and undisclosed income sustained as assessee itself claim payment of cash in the civil suit and failed to explain the source of the cash payment.

Only assessee can sign Form number 35A prescribed under Income Tax (Dispute Resolution Panel) Rules, 2009

August 31, 2023 11136 Views 1 comment Print

In present facts of the case, it was observed by the Tribunal that only Assessee could sign Form number 35A prescribed under Income Tax (Dispute Resolution Panel) Rules, 2009.

Communication relating to assessments, appeals, orders without DIN are null & void

August 31, 2023 1248 Views 0 comment Print

In present facts of the case, the Tribunal held that Assessment Order issued without DIN is null and void as it is in violation of CBDT Circular No. 19/2019 dated 1 4th August, 2019.

Section 148 Notice Void if AO Doesn’t examine Assessee’s Filed Return

August 31, 2023 6387 Views 0 comment Print

ITAT Delhi rules on the invalidity of a notice issued without accessing an assessee’s return, showcasing the nuances of the Income Tax Act.

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