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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 u/s. 148 quashed as matter already decided in favour of assessee by PCIT: Delhi HC

October 15, 2024 387 Views 0 comment Print

Delhi High Court held that reopening of assessment u/s. 148 of the Income Tax Act unsustainable as PCIT already decided the matter in favour of the assessee while invoking revisionary powers u/s. 263 of the Income Tax Act. According, reassessment action quashed.

Reassessment u/s. 148 based on mere change of opinion impermissible: Gujarat HC

October 14, 2024 648 Views 0 comment Print

Gujarat High Court held that reopening of assessment under section 148 of the Income Tax Act on mere change of opinion is not permissible in law. Accordingly, petition allowed and reassessment notice quashed.

Reopening of assessment based on mere change of opinion unsustainable: ITAT Delhi

October 14, 2024 459 Views 0 comment Print

ITAT Delhi held that mere change of opinion would not confer jurisdiction upon the Assessing Officer to reopen proceedings without anything further. Thus, reopening of assessment under section 147 of the Income Tax Act set aside.

Reassessment u/s. 148 based on cryptic reasons and mechanical approval quashed: ITAT Delhi

October 14, 2024 693 Views 0 comment Print

ITAT Delhi held that the issuance of notice u/s. 148 based on cryptic reasons combined with a mechanical approval of the Pr.CIT u/s. 151 of the Income Tax Act do not pass the test of judicial scrutiny. Thus, reassessment quashed.

CIT(A) sent Notices to wrong Email ID: ITAT Remits Appeal for Reassessment 

October 14, 2024 177 Views 0 comment Print

ITAT remits Venkataraju Chandra Shekar’s case for reassessment after notices were sent to the wrong email, impacting appeal hearing. Fresh adjudication ordered.

Email Notices Despite Request for Physical Notices: ITAT Sets aside CIT(A)’s Ex Parte Order

October 14, 2024 399 Views 1 comment Print

ITAT sets aside CIT(A) dismissal of Luv Procon’s appeal due to email notices despite a request for physical communication. Delay condoned; fresh hearing ordered.

Best Judgment Assessment: ITAT Directs Fresh Order as AO failed to consider ITR

October 14, 2024 255 Views 0 comment Print

ITAT Ahmedabad directs a fresh assessment after AO ignored filed ITR in Govindbhai Hirabhai Bharvad case, due to ex-parte assessment and delay issues.

Section 148A(b) sent to outdated email ID: HC set-aside order & Notices

October 14, 2024 72 Views 0 comment Print

Karnataka HC sets aside Azeem Infinite’s tax assessment as notices were sent to an email created by a former accountant. Case remitted to Section 148A(b) stage.

ITAT Mumbai direct AO to compute addition at 3% of Bogus Purchase

October 10, 2024 675 Views 0 comment Print

ITAT Mumbai grants partial relief to Ramniklal & Sons in the bogus purchase case, directing reassessment based on judicial precedents.

Addition towards income from undisclosed source sustained due to deliberate failure to produce all books: ITAT Delhi

October 9, 2024 234 Views 0 comment Print

ITAT Delhi held that addition under section 69A on account of income from undisclosed source sustained in assessee deliberately failed to produce all the books of accounts and no material evidence furnished by the assessee.

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