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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 525 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 888 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 2883 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 18288 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 2205 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 4323 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 42780 Views 2 comments Print


Latest Judiciary


Addition Deleted Due to Pure Estimation on Borrowed Satisfaction Without Verification

Income Tax : The case examined reassessment based on third-party information without independent application of mind. The Tribunal ruled that r...

May 5, 2026 201 Views 0 comment Print

Interest on VAT is Compensatory, Not Penal – ITAT Allows Deduction

Income Tax : The Tribunal relied on Supreme Court precedent to hold that interest on tax arrears is compensatory, not penal. It ruled that such...

May 4, 2026 63 Views 0 comment Print

No Specific Charge = No Penalty – ITAT Deletes 270A Penalty for Vague Notice Bonafide Claim

Income Tax : The Tribunal held that absence of a clear charge in the penalty notice makes the proceedings invalid. It ruled that failure to spe...

May 4, 2026 126 Views 0 comment Print

ITAT Hyderabad Quashes Reassessment Due to Time-Barred Section 148 Notice

Income Tax : The case examined validity of a reassessment notice issued beyond statutory limits. The ITAT held the notice invalid as it exceede...

May 4, 2026 423 Views 0 comment Print

Reopening of Assessment Upheld Due to Form 26AS Showing Undisclosed Contract Income

Income Tax : The Tribunal upheld reopening under Section 147 as Form 26AS reflected substantial contract receipts despite no return being filed...

May 3, 2026 183 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 5757 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 819 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 10275 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 5787 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 5886 Views 0 comment Print


Allahabad HC Quashed Section 148 reassessment Notice for A.Y. 2014-15

September 5, 2022 1470 Views 0 comment Print

Priya Vs ITO (Allahabad High Court) Heard Sri Rahul Agarwal, learned counsel for the petitioner and Sri Gaurav Mahajan, learned counsel for the respondent nos. 1 and 2/ Income Tax Department. This writ petition has been filed praying, inter alia, for the following relief:- “(i) Issue a writ, or direction in the nature of certiorari […]

Income Tax Reassessment without supplying reason is Invalid

August 29, 2022 2673 Views 0 comment Print

Recording of reasons before initiation of reassessment proceedings & communication thereof to assessee is sine qua non that goes to root of matter

Bombay HC stayed Section 148 proceedings for AY 2014-15

August 27, 2022 13080 Views 2 comments Print

Bombay High Court stayed proceedings under Section 148 of Income Tax Act for AY 2014-15. Initial notice was issued after time limit expired

Bogus accommodation entries – HC upheld validity of Section 148 Notice

August 25, 2022 2787 Views 0 comment Print

Rochana Agarwal Vs ACIT (Allahabad High Court) The reason for issuing the notice under Section 148 of the Act is that during investigation, the Assessing Officer has gone through the income tax return and other related documents of the assessee and has found that the M/s KCGP Share Broking Service Pvt. Ltd. has been used […]

Carry out due verification before initiating Section 148/147 proceedings: CBDT

August 22, 2022 15309 Views 0 comment Print

Consequent to order passed by Allahabad High Court passing severe strictures and proposing to levy exemplary cost of Rs 50 lakhs in a writ challenging reopening of assessment on wrong facts,  CBDT today ( 22nd August, 2022 ) has issued instructions to all its officers that for initiating proceedings under Section 148/147 of the Act, […]

Allahabad HC imposed Cost of Rs. 50 Lakh on Department for creating illegal Income Tax demand

August 17, 2022 24873 Views 1 comment Print

Allahabad HC quashed Income Tax reassessment Order notices for violating principle of natural justice & imposed Rs. 50 Lakh cost on Officers

What is assessment under the income tax act, 1961, and How many types of it are there?

August 16, 2022 78639 Views 0 comment Print

Understanding assessment under the income tax act, 1961. Learn about the different types of assessments and their implications for taxpayers.

Proceedings for A.Y 2013-14 & 2014-15 cannot be reopened beyond 4 years

August 3, 2022 7065 Views 2 comments Print

Understanding the time limit for reopening proceedings for A.Y 2013-14 & 2014-15 under the old provisions. Learn the implications and exceptions.

Usurpation of jurisdiction by AO to reopen assessment is legally untenable

August 1, 2022 615 Views 0 comment Print

Srijal Gupta Vs ITO (ITAT Amritsar) After a thoughtful observation of the fact of the case we decided that the reopening was made u/s. 148 related to purchase of property amount to Rs.9,53,750/-. But after completion of assessment, the ld. AO had accepted the assessee’s investment and had not added any amount related to source […]

Revised Guideline for Issue of Section 148 Notice

August 1, 2022 91644 Views 1 comment Print

Salient features of new Section 148 to 151A ‘i.e. assessment/reassessment procedure of Income Escaping Assessment

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