Follow Us:

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 513 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


HC surprised with reasons recorded for reopening & hoped for better reasons

February 23, 2022 2346 Views 0 comment Print

Nirmal Bang Securities Pvt Ltd Vs ACIT (Bombay High Court) In this case reasons quoted were bereft of any material as AO quoted that search information is received with regard to accommodation entry But  does not indicate what address was searched, from whom such information was received, what date the search happened, what date the […]

HC dismisses Reassessment Notice to Tata Sons Based on mere change of opinion

February 20, 2022 1158 Views 0 comment Print

Tata Sons Limited Vs DCIT (Bombay High Court) Bombay High Court find substance in the submission of Mr.Pardiwalla that the case at hand is nothing but an instance of mere change of opinion. A bare perusal of the reasons indicates that the exercise was infuenced by a mere change of opinion. To start with, it […]

Failure to issue section 143(2) notice prior to finalising reassessment order makes reassessment proceedings a nullity

February 7, 2022 7617 Views 0 comment Print

ACIT Vs P & R Infraprojects Ltd. (ITAT Delhi) A perusal of the assessment order as well as the order of the CIT(A) shows that no notice u/s 143(2) was ever issued to the assessee before completing the assessment u/s 143(3)/147. It is the submission of the ld. Counsel that it is mandatory to issue […]

Division Bench of Rajasthan HC Quashes Section 148 notices in 472 cases

January 28, 2022 3582 Views 0 comment Print

Introduction: – The Division Bench of Hon. Rajasthan High Court consisting of Chief Justice Akil kureshi and Justice Sameer Jain. in Sudesh Taneja vs. ITO DB W.P No.969/2022. Order dated 27.01.22 quashed the reassessment notices issued after 31.03.21. Earlier the Ld. Single judge of Hon. Rajasthan HC had quashed reassessment notices u/s 148 of the […]

Rajasthan HC quashes Section 148 Notice issued after 31.03.2021 in 472 Cases

January 28, 2022 13773 Views 0 comment Print

Sudesh Taneja Vs ITO (Rajasthan High Court) In the writ petitions the petitioners have challenged respective notices issued by the Assessing Officers under Section 148 of the Income Tax Act, 1961 (‘the Act’ for short) for reopening assessments for various assessment years. All these notices have been issued after 01.04.2021 and pertain to relevant period […]

HC Quashes Section 147 Assessment as reason for reopening was not sustainable

January 28, 2022 3180 Views 0 comment Print

Giraben Atulbhai Shah Vs ACIT (Gujarat High Court) The objections raised by the assessee came to be disposed of by the Assessing Officer vide his order dated 16th November 2021 stating that the assessee sold immovable property for an aggregate value of Rs.52 Lakh and the same was not offered for tax in the return […]

Reopening of Assessment not permissible for Change of Opinion of AO

January 24, 2022 14337 Views 0 comment Print

Oracle Financial Services Software Limited Vs DCIT (Bombay High Court) Existence of the reason to believe that income chargeable to tax has escaped assessment is a jurisdictional condition for invoking the power under section 147 of the Act, 1961, both within and beyond a period of four years from the end of relevant assessment year. […]

Reassessment notice quashed for failure of AO to follow statutory formalities

January 21, 2022 3942 Views 0 comment Print

Reassessment notice was quashed with liberty to AO concerned to initiate fresh re-assessment proceedings in accordance with the relevant provisions of the Act as amended by Finance Act, 2021 and after making compliance of the formalities as required by the law.

Reopening of Assessment not permissible to take another view on same material

January 18, 2022 6393 Views 0 comment Print

Vodafone Idea Ltd. Vs ACIT (Bombay High Court) The entire basis for proposing to reopen, as can be seen from the reasons, is on the documents and submissions which were available before the Assessing Officer, before passing of the original assessment order. In fact, in the reasons, it is also recorded that the same issue […]

Taxability of remuneration/interest not claimed by partnership firm in the hands of partners- HC Quashes assessment order

January 18, 2022 4173 Views 0 comment Print

Mamta Bhavesh Dave Vs ITO (Gujarat High Court) ITAT adjudicated the controversy as regards the deduction of remuneration/interest on the partners capital not claimed by the assessee i.e. the partnership firm in its profit and loss account. The Tribunal took notice of the fact that the CIT Appeals had directed to tax the amount of remuneration/interest […]

Search Post by Date
May 2026
M T W T F S S
 123
45678910
11121314151617
18192021222324
25262728293031