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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 2841 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 69 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 105 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 96 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 90 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 447 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 5742 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


Sec 263 Quashed; AO Probed Renuka Mata Society Credits; No Revision on Suspicion: ITAT Ahmedabad

February 17, 2026 306 Views 0 comment Print

The Tribunal ruled that Section 263 cannot be invoked merely because the Commissioner holds a different opinion. Once adequate inquiry is conducted and a reasonable view is taken, revision is unsustainable.

Salary in NRE A/c Not Taxable; Foreign Employment Income Received Outside India: ITAT Ahmedabad

February 17, 2026 639 Views 0 comment Print

Once the Tribunal ruled that foreign salary was not taxable in India, consequential additions for alleged unexplained investments and deposits were also deleted. The appeal was allowed in full.

Sec 147 Reopening After 4 Years Invalid; Audit Objection Not Tangible; Bad Debt MAT Issue Fails: ITAT Mumbai

February 17, 2026 300 Views 0 comment Print

The Tribunal ruled that reopening based merely on audit objection without independent application of mind is unsustainable. An audit note cannot replace the Assessing Officers reasoned belief.

Reassessment Quashed: ₹50L Threshold Not Met; GP Addition Held Double Taxation; Bogus Purchase Case Won: ITAT Ahmedabad

February 17, 2026 474 Views 0 comment Print

The decision clarifies that the monetary threshold under Section 149 applies to actual taxable income, not purchase turnover. As the addition fell below ₹50 lakh, reassessment proceedings were invalid.

Bogus Purchase Addition U/s 69C Deleted – Export Sales Stock Records Proved Genuineness: ITAT Mumbai

February 17, 2026 432 Views 0 comment Print

The Tribunal emphasized that without physical goods, exports and stock reconciliation would not be possible. Since quantitative records and gross profit remained consistent, the addition under Section 69C was deleted.

Vivad Se Vishwas Benefit Cannot Be Denied When Penalty Appeal Is Pending: Bombay HC

February 17, 2026 390 Views 0 comment Print

The Bombay High Court held that a pending penalty appeal qualifies as a “dispute” under the Vivad Se Vishwas Scheme. Rejection solely for absence of assessment appeal was set aside

ITAT Rajkot Upholds Sec 263; Failure to Verify Share Capital Source of Source Makes Order Erroneous

February 17, 2026 384 Views 0 comment Print

The Tribunal ruled that accepting share capital and unsecured loans without proper verification violates Section 68 requirements. It upheld the Principal CITs revision order, stating that failure to investigate renders the order prejudicial to revenue.

Section 148 Notice Invalid Since Issued After Surviving 23-Day Limitation Period

February 17, 2026 2580 Views 0 comment Print

The Tribunal held that the fresh notice issued under Section 148 was beyond the surviving limitation period available after applying TOLA and Supreme Court directions. As a result, the reassessment proceedings were declared void ab initio.

Sec 263 Upheld; Lack of AO Enquiry on Stock Anomaly Made Reassessment Erroneous: ITAT Raipur

February 17, 2026 336 Views 0 comment Print

The Tribunal ruled that failure to verify discrepancies in quantitative stock details justified revisionary action. Mere calling of documents without proper examination invites Section 263 proceedings.

Rural Agricultural Land Case Restored; No Dismissal for Non-Prosecution; Capital Gain Remand – ITAT Pune

February 17, 2026 375 Views 0 comment Print

The ITAT ruled that dismissing an appeal solely for non-compliance is contrary to law. The appellate authority is obligated to frame issues and pass a reasoned order on each ground raised.

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