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Section 147

Latest Articles


ITAT Upholds Addition for Bogus LTCG from Penny Stocks

Income Tax : ITAT Ahmedabad confirms Section 68 addition of ₹93.92 lakh for bogus LTCG from Kushal Tradelink shares, rejecting the appeal bas...

November 9, 2025 1506 Views 0 comment Print

FAQs on Assessments under Income-tax Law

Income Tax : Learn about various types of income tax assessments under Sections 143, 144, and 147, their procedures, time limits, and taxpayer ...

November 4, 2025 90126 Views 7 comments Print

FAQs on Maintenance of books of accounts under Income Tax Act, 1961

Income Tax : Section 44AA mandates books for professionals and businesses exceeding income thresholds. Details presumptive tax rules, required ...

October 31, 2025 3537 Views 0 comment Print

Reopening on Borrowed Belief from ACB Quashed – Tribunal holds 147 invalid & 263 unsustainable

Income Tax : Ahmedabad ITAT quashes reassessments based on ACB report, ruling the AO lacked independent "reason to believe" and only used borro...

October 26, 2025 483 Views 0 comment Print

Time limit for issuing different income-tax notices & completion of assessment

Income Tax : Summary of statutory deadlines for issuing income tax notices (Sec 143, 147) and completing assessments, reassessments, and appeal...

October 17, 2025 23331 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 1578 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 3324 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 7227 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 13101 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 42249 Views 2 comments Print


Latest Judiciary


Addition Deleted Because Recorded Sales Cannot Be Taxed Again Under Section 68

Income Tax : The Tribunal held that once sales are accepted in audited books, they cannot be reclassified as unexplained cash credits. The addi...

November 15, 2025 6 Views 0 comment Print

Reassessment Quashed for Using Section 147 Instead of Mandatory Section 153C

Income Tax : The Tribunal ruled that reassessment under section 147 was invalid where the basis of information stemmed from a third-party searc...

November 15, 2025 33 Views 0 comment Print

60% Tax Disallowed Because Higher 115BBE Rate Applies Only From AY 2018-19

Income Tax : The Tribunal held that substantial bank deposits without filing a return provided adequate basis to reopen under section 147. Noti...

November 15, 2025 51 Views 0 comment Print

ITAT Holds Dismissal Invalid Where Assessee Not Heard on Section 249(4)(b) Requirement

Income Tax : The Tribunal held that the CIT(A) erred in dismissing the appeal solely for non-payment of advance tax without first seeking clari...

November 15, 2025 42 Views 0 comment Print

ITAT Cuts Demonetisation Addition After Finding Books Reliable

Income Tax :  ITAT Chandigarh allowed a delayed appeal of 457 days, holding that the assessee had reasonable cause for delay and the Limitatio...

November 15, 2025 36 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 4998 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 435 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 9777 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 5058 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 5673 Views 0 comment Print


ITAT Quashes Reassessment: Escaped Income Below Rs. 50 Lakh Bars Extended Time Limit Reason

October 10, 2025 870 Views 0 comment Print

This decision strengthens the protection against time-barred reassessment, emphasizing that the extended limitation under Section 149(1)(b) applies only if the escaped income is factually above ₹50 lakh. The ITAT confirmed the reassessment was invalid as the AO’s final order confirmed the escaped income was much lower than the extended limit required for reopening

No Retrospective Remand: ITAT Scraps CIT(A)’s Order in Bogus LTCG Case for Wrongly Invoking New Law

October 10, 2025 321 Views 0 comment Print

The ITAT ruled that the CIT(A) cannot set aside a reassessment order framed under Section 147 read with Section 144B, as the limited power to remand only applies to best-judgment assessments under Section 144. The Tribunal sent the penny stock LTCG case back, directing the CIT(A) to decide the appeal strictly on its merits.

Reopening u/s 147 quashed – AO’s “fishing enquiry” to investigate offshore receipts not valid formation of belief- Reassessment void where AO reopens only to verify PE/offshore claims

October 9, 2025 399 Views 0 comment Print

The ITAT Delhi invalidated the reassessment proceedings against Huawei International, a Singapore resident, for AY 2014-15. The Tribunal ruled that the AO’s attempt to investigate offshore software receipts, based merely.

ITAT Delhi remands ₹16.10 Cr unsecured – loan issue for verification; consequential interest disallowance also to be re-examined – CIT(A) erred in bypassing remand report

October 9, 2025 198 Views 0 comment Print

The ITAT Delhi set aside the CIT(A)’s order deleting a Rs.16.10 Cr unsecured loan addition against Nitin Garg, remanding the issue to the AO. The Tribunal found the CIT(A) erred by not requesting a remand report to verify the lender’s creditworthiness and the source of funds, despite the assessee’s non-compliance during assessment.

ITAT Rajkot Upholds ₹3.99 Crore Addition u/s 56(2)(viib) – Rejects DCF Valuation as Defective & Unsubstantiated

October 9, 2025 321 Views 0 comment Print

The ITAT Rajkot confirmed the addition of Rs.3.99 crore to the income of Kataria Snack Pellets Pvt. Ltd. under Section 56(2)(viib), ruling that the company’s Discounted Cash Flow (DCF) share valuation was speculative, lacked empirical support for growth rates and terminal value, and failed to adhere to ICAI guidelines.

You’re Still Taxed After You’re Gone- But Your Heir Only Pays What’s in the Cupboard

October 8, 2025 369 Views 0 comment Print

ITAT Jaipur holds u/s 159 that penalty survives assessee’s death and is enforceable against the legal heir. Recovery is strictly limited to the value of the inherited assets or estate.

No addition based solely on a third-party document denied by assessee

October 8, 2025 249 Views 0 comment Print

Where the only piece of evidence, AO possessed was the ‘Iqrarnama’, which was not found in the assessee’s possession, was not in their handwriting, and did not bear their genuine signatures, no addition could be made to the assessee’s income, treating it as unexplained money and interest.

“Make-Available” Clause Saves Pratt & Whitney – Wins ₹242 Cr FTS Dispute- Aircraft Engine Repair Abroad Not FTS – Tribunal Holds No Transfer of Know-How to Indian Clients

October 8, 2025 189 Views 0 comment Print

Delhi ITAT ruled that Pratt & Whitney’s overseas aircraft engine repair is not Fees for Technical Services (FTS) as it fails the DTAA’s “make-available” test. The ₹242 Cr demand was deleted.

Reassessment u/s 148A by Jurisdictional AO beyond scope of Sec 151A quashed by Karnataka HC

October 7, 2025 582 Views 0 comment Print

Karnataka HC quashes reassessment and penalty orders after finding the Jurisdictional AO initiated Sec 148A proceedings outside the scope of the Faceless Regime (Sec 151A).

Delhi HC Upholds Reopening Based on ‘Yes, I Am Convinced’ Approval

October 7, 2025 573 Views 0 comment Print

Delhi High Court upheld reassessment for Agroha Fincap, ruling that the sanction “Yes, I am convinced it is a fit case” meets Section 151 requirements, rejecting the ITAT’s finding of mechanical approval.

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