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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


Reopening after 4 Years in absence of failure of Assessee to disclose fully & truly all materials was invalid

September 26, 2021 1221 Views 0 comment Print

CIT Vs John Ettimootil Samuel (Madras High Court) The Tribunal, in our view, rightly took note of the fact that the reopening of the assessment was after four years and there was no tangible material to establish that the assessee failed to disclose fully and truly all materials, which are required for the assessment at […]

Reopening based on seized material not belonging to assessee is void ab-initio

September 26, 2021 1059 Views 0 comment Print

Green Park Estate Pvt. Ltd. Vs ACIT (ITAT Delhi) A perusal of the reasons recorded in the case of the assessee as well as in the case of M/s Green Valley Tower Ltd. are identical on the issue of alleged interest paid on post dated cheuqes. We have also gone through the paper book containing […]

Faceless Assessment in Cases in which limitation period expires on 30.09.2021

September 22, 2021 2289 Views 0 comment Print

Central Board of Direct Taxes hereby directs that in addition to the exclusion of the cases in the said Orders, cases (a) set aside to be done de novo or (b) to be done u/s 147 of the Act

Section 148 notice invalid for reassessment initiated based on incriminating material

September 21, 2021 8337 Views 0 comment Print

On the basis of incriminating material found, once reassessment proceedings was initiated on the basis of incriminating material found in the search of 3rd party then the provisions of section 153C of the I.T. Act were applicable which exclude the application of section 147 and 148 of the I.T. Act and notice u/s. 148 of the Act and proceeding u/s. 147 are illegal and void ab initio

Reopening For Mere Non -Ratification of Section 10B approval not justified

September 20, 2021 963 Views 1 comment Print

Indus Teqsite Private Ltd. (presently known as Data Patterns India Pvt. Vs DCIT (Madras High Court) Merely because the ratification has not been done by a Higher Authority, will it automatically vitiate the approval, which was granted by the Competent Authority namely the Development Commissioner. The learned Single Judge, after noting that the said assessee […]

No TDS on Sale of Software by treating it as Royalty

September 20, 2021 3801 Views 0 comment Print

Financial Software and Systems Private Limited Vs CIT (Madras High Court) The question of law which is involved is with regard to whether the assessee was liable to deduct Tax at Source in respect of the Computer Software which was dealt with by them, procured from a Non-Resident and sold in the Indian Market. This […]

ITAT quashes section 147/148 proceeding as reasons to believe not existed anymore

September 15, 2021 6885 Views 0 comment Print

Bansiwala Iron & Steel Rolling Mills Vs DCIT (ITAT Jaipur) Since the A.O. is a quasi-judicial authority, who has to collect the evidences, material and then to adjudicate the matter after due and complete application of mind. The A.O. expected to record his own satisfaction before reaching to any conclusion. In our view, the A.O. […]

ITAT remands case back to AO- Reassessment based on change of opinion

September 15, 2021 3315 Views 0 comment Print

Magma HDI General Insurance Co. Ltd. Vs. ITO (Calcutta High Court) Mr. Dutta could not satisfy this Court about what new material of documents came into the possession of the Assessing Officer after the order of assessment under Section 143(3) of the Act, which were not produced by the assessee before the Assessing Officer in […]

Quashing of reassessment was invalid if opportunity was provided to assessee to submit additional objections

September 13, 2021 1098 Views 0 comment Print

Dr. Sajan Hedge Vs ACIT (Madras High Court) Conclusion: Instead of quashing the entire reassessment proceedings, it was suffice if an opportunity was provided to assessee to submit additional objections, if any, based on the materials relied on by assessee to AO, within a stipulated period and on receipt of the same, AO should be […]

Limitation period for revisional proceeding in case of both Assessment & Reassessment

September 5, 2021 1746 Views 0 comment Print

CIT Vs Indian Overseas Bank (Madras High Court) The question as to whether the date, on which the order under Section 147 of the Act was passed should be reckoned as the starting point of limitation, considering the facts and circumstances of the case, has been dealt with by several decisions of the Hon’ble Supreme […]

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