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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 2844 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 18264 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 93 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 114 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 108 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 93 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 453 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 5745 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


Extended time under TOLA not available for Sanction by Specified Authority U/S 151

March 28, 2023 4617 Views 1 comment Print

Explore the complexities surrounding the validity of re-assessment proceedings under Section 147/148A of the Income Tax Act, focusing on the impact of the Taxation & Other Laws (Relaxations & Amendments of Certain Provisions) Act, 2020 (TOLA) and the amendment through the Finance Act, 2021.

Reopening by merely quoting Insight portal information is invalid

March 28, 2023 6795 Views 0 comment Print

The impugned notice, other than merely quoting that the Insight portal contains information as stated by the Assessing Officer in his reasons for the re­opening, does not further investigate the information or come to an independent assessment connecting the petitioner to the particular transactions specified in the information.

Draft submission regarding approval u/s 151 from competent authority for issue of notice u/s 148

March 28, 2023 9807 Views 1 comment Print

Explore the intricacies of approval under Section 151 of the Income Tax Act for the issuance of notices under Section 148. Uncover legal nuances and key judgments.

Reassessment proceedings without any new tangible material is unsustainable in law

March 25, 2023 1293 Views 0 comment Print

Bombay High Court held that re-assessment proceedings, in absence of any failure to disclose any material fact and without any new tangible material which was not available at the time of passing of the original assessment order, is unsustainable.

Another Reassessment Notice Cannot be Issued by AO for Same AY

March 25, 2023 10992 Views 0 comment Print

As per Section 147 of the Income Tax Act, 1961, the Income Tax Department has the power to reassess an individual’s previously filed income tax returns. The Assessing Officer can pick income tax return for reassessment subject to some pre-defined criteria by sending a notice under section 148 for income Escaping Assessment.

Reasons for reopening found to be non-existent, such defect is not curable by applying section 292B

March 24, 2023 2478 Views 0 comment Print

ITAT Delhi held that AO drew belief on the reasons which were later found to be totally non-existent. Such defect in the reasons cannot be ascribed as a mere technical irregularity and consequently defect cannot be cured by applying Section 292B of the Income Tax Act.

Reassessment proceedings invalid as no failure in disclosing any material facts

March 24, 2023 1905 Views 0 comment Print

Bombay High Court held that initiation of reassessment proceedings invalid as there was no failure on the part of the assesse to disclose any material facts.

Current profit not to be included in accumulated profit to determine deemed dividend

March 20, 2023 1485 Views 0 comment Print

ITAT Mumbai held that while determining the amount of deemed dividend under Explanation 2 to Section 2(22)(e) of the Income Tax Act, the current profit is not to be included to be part of accumulated profit.

Subsequent revisional order tends to be invalid as original re-assessment order passed invalidly

March 15, 2023 1449 Views 0 comment Print

Orissa High Court held that when original re-assessment order was not passed validly, subsequent revisional order passed by PCIT is held to be invalid.

Reassessment proceedings without issuance of notice u/s 143(2) is bad in law

March 14, 2023 7617 Views 0 comment Print

ITAT Delhi held that reassessment proceedings without issuance of notice under section 143(2) of the Income Tax Act is bad in law and liable to be quashed.

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