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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 3930 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1647 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 900 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2490 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 153 Views 0 comment Print

Retrospective Amendment Doesn’t Justify Reassessment Beyond Four Years

Income Tax : Bombay High Court sets aside IT reassessment against Oxford University Press, ruling no failure to disclose material facts for reo...

March 8, 2025 105 Views 0 comment Print

No valid assessment or reassessment can be made in name of deceased: ITAT Mumbai

Income Tax : ITAT Mumbai held that once the assessee is dead no valid assessment or reassessment can be made in the name of the deceased. Thus,...

March 7, 2025 321 Views 0 comment Print

Issue of reopening notice u/s. 148 by ACIT-Jaipur illegal as jurisdiction lies with ITO-Delhi

Income Tax : ITAT Jaipur held that issuance of notice under section 148 of the Income Tax Act by ACIT, Jaipur, is illegal and liable to be quas...

March 6, 2025 150 Views 0 comment Print

Reopening of assessment based on borrowed satisfaction not sustainable: Gujarat HC

Income Tax : Gujarat High Court held that reopening of assessment based on borrowed satisfaction without there being any link between informati...

March 6, 2025 87 Views 0 comment Print


Latest Notifications


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 246 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 9243 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 4068 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 5511 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 3021 Views 0 comment Print


Reassessment not valid if no application of mind by AO: ITAT Pune

March 2, 2025 642 Views 0 comment Print

Aadhunik Infrastructure Development Pvt. Ltd. Vs DCIT (ITAT Pune) The Income Tax Appellate Tribunal (ITAT), Pune Bench “A,” has ruled in favor of Aadhunik Infrastructure Development Pvt. Ltd. (formerly Gauri Plasticulture Pvt. Ltd.), setting aside the reassessment proceedings initiated under Section 147 of the Income Tax Act, 1961, for the Assessment Year 2012-13. The appeal […]

Capital gain cannot be treated as bogus merely on warning letter of SEBI without any incriminating material

February 28, 2025 1743 Views 0 comment Print

ITAT Chandigarh held that treating capital gains earned on sale of shares as bogus merely on the basis of warning letter of SEBI without any incriminating material found during course of search demonstrating transaction as bogus is unjustified.

No Reassessment After 4 Years for AO’s Error in Computing Income When Material Facts Fully Disclosed

February 28, 2025 1215 Views 0 comment Print

Bombay High Court invalidates reassessment notice under Section 148 of the Income Tax Act, citing failure to meet jurisdictional conditions under Section 147.

Initiation of revision proceedings u/s. 263 based on audit objection not tenable in law: ITAT Jaipur

February 28, 2025 642 Views 0 comment Print

ITAT Jaipur held that exercise of revisionary power under section 263 of the Income Tax Act on the basis of audit objection is not tenable in law. Accordingly, initiation of proceedings liable to be quashed.

Order passed u/s. 148A(d) beyond 3 years with approval of PCIT instead of PCCIT quashed

February 28, 2025 453 Views 0 comment Print

ITAT Pune held that approval of Principal Chief Commissioner of Income Tax [PCCIT] required for order passed under section 148A(d) of the Income Tax Act beyond three years from the end of assessment year.

No Reassessment on Change of Opinion or Solely on Insight Portal Data: Gujarat HC

February 28, 2025 843 Views 0 comment Print

Gujarat High Court sets aside reassessment notice under Section 148 issued to Khushboo Anand Bhayani for F&O trading profits, citing lack of independent verification.

Section 69 Addition: ITAT Directs CIT(A) to Reassess Case & Consider Additional Evidence

February 28, 2025 1689 Views 0 comment Print

ITAT Ahmedabad remands case due to incorrect notice delivery, allowing reassessment of unexplained deposits and income under natural justice principles.

Substantive Additions Require Evidence; Protective Additions Apply to Ownership Uncertainty

February 27, 2025 201 Views 0 comment Print

ITAT Ahmedabad rules on undisclosed foreign accounts in the case of Manjulaben Bipinbhai Patel vs DCIT, addressing tax assessments and legal implications.

Rajasthan HC quashes section 148 notice for Vague & Incomplete Information

February 27, 2025 657 Views 0 comment Print

Rajasthan High Court quashes IT notice against Prateek Bulls and Bears Pvt Ltd due to lack of evidence linking bank account to the assessee. 

Reassessment Invalid without Fresh Notice when No Addition made on Reopened Issue: ITAT Pune

February 27, 2025 117 Views 0 comment Print

ITAT Pune held that when no addition has been made on account of which the case was reopened, the Assessing Officer cannot make any other addition without issuing a fresh notice u/s 148 of the Act.

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