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Section 147

Latest Articles


Tax on Property Transactions: Section 56(2)(vii)(b) & Reassessment Proceedings

Income Tax : Explore tax implications under Section 56(2)(vii)(b) and reassessment norms in property transactions. Judicial rulings emphasize e...

April 20, 2025 6096 Views 0 comment Print

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 7515 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 2529 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 2226 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 996 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 1239 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 2868 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 7092 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 12996 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 41964 Views 2 comments Print


Latest Judiciary


Reopening u/s. 147 quashed as based on vague reasons and non-application of mind

Income Tax : ITAT Kolkata held that the reopening of assessment cannot be allowed on the basis of vague reasons, where AO has not done anything...

May 19, 2025 48 Views 0 comment Print

Notice u/s. 148 issued beyond time period specified u/s. 149(1) is invalid: Bombay HC

Income Tax : Bombay High Court held that notice issued under section 148 of the Income Tax Act beyond the time period specified under section 1...

May 19, 2025 123 Views 0 comment Print

ITAT Restores Case to CIT(A) After 5 Missed Hearings, Including One During Covid

Income Tax : Pune ITAT sends assessee's tax appeal back to CIT(A) for re-adjudication after five missed hearings, including one during the Covi...

May 18, 2025 108 Views 0 comment Print

Madras HC Sets Aside Assessment Order; Grants Taxpayer Opportunity to File Reply with New Evidence

Income Tax : Madras High Court orders tax re-assessment for teacher who claimed account misuse by bank manager, citing prior fraud case and den...

May 18, 2025 150 Views 0 comment Print

Section 148 notice not served: ITAT Restores Bar Council Case to NFAC

Income Tax : ITAT Delhi restores Bar Council case to NFAC, directing review of mandatory notice service under Section 148 for reassessment befo...

May 17, 2025 345 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 4437 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 297 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 9522 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 4578 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 5553 Views 0 comment Print


Addition on grounds not forming part of reasons recorded for reopening of assessment not tenable

January 20, 2025 231 Views 0 comment Print

ITAT Ahmedabad held that addition on grounds other than grounds forming part of reasons recorded for reopening of assessment not justified. Accordingly, addition towards unexplained investment which didn’t form part of reasons liable to be deleted.

Ground not addressed by CIT(A) cannot be taken up by ITAT: Delhi HC

January 20, 2025 414 Views 0 comment Print

Delhi High Court held that ITAT cannot address the ground which remained unaddressed by CIT(A). Accordingly, matter restored back to CIT(A) to decide on the grounds that were not decided.

Provision for leave salary not allowable as deduction u/s. 43B(f): Madras HC

January 18, 2025 1524 Views 0 comment Print

Madras High Court held that provision for leave salary is not allowable as deduction under section 43B(f) of the Income Tax Act since deduction of actual payment is allowable and not of provision. Accordingly, question of law answered in favour of revenue.

Both the parties agreed to treat the addition as business receipts: ITAT directed AO to assess profit @ 8%

January 18, 2025 1197 Views 0 comment Print

Assessee didnot file return for the year under consideration. As per AIMS module information received that assessee has deposited the amount of Rs.16,84,100/- as cash during the demonetization period. Case was reopened notice was issued accordingly.

S.159 applies when reassessment notice was issued during lifetime of deceased assessee

January 18, 2025 1125 Views 0 comment Print

In response to the said notice, the son/legal heir of the deceased assessee submitted a reply on 01 April 2023 wherein he unequivocally apprised the respondent of the demise of his father/assessee, furnishing alongwith a copy of the death certificate as conclusive evidence, and asserted that the notice was null and void ab initio.

ITAT Grants Assessee Another Opportunity Due to Health & Personal Challenge

January 18, 2025 423 Views 0 comment Print

ITAT Ahmedabad allows Pankajkumar Patel’s appeal for statistical purposes, remanding unexplained investment case to AO for reconsideration under Section 69A.

ITAT Reduces Gross Margin on Unaccounted Cash Receipts to 6% Considering All Facts

January 18, 2025 525 Views 0 comment Print

Summary of appeal challenging CIT(A) order on income tax assessment for AY 2013-14. Key issues include Section 147 validity and profit estimation.

ITAT Restores Ex Parte Assessment Order U/s.144 Due to Assessee’s Old Age

January 18, 2025 501 Views 0 comment Print

ITAT Delhi remits Vinod Kumar Garg’s 2012-13 tax assessment case back to AO for reevaluation. Key issues include unexplained investments and procedural lapses.

Directs AO to Reassess ₹92 Lakh Addition & Determine Commission on Accommodation Entry

January 18, 2025 381 Views 0 comment Print

ITAT Ahmedabad narrows PCIT’s directions under Section 263 in Vimal Agarwal’s tax case for AY 2014-15, limiting inquiry to commission on ₹92 lakh entry.

Reopening Proceedings for Verification Without Substantive Reason Is Legally Invalid

January 18, 2025 408 Views 0 comment Print

ITAT Delhi quashes reopening of assessment for verification in JHM Developers Pvt Ltd vs ITO case, ruling it legally invalid.

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