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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


Reassessment was erroneous in absence of prima facie finding by CIT

September 4, 2021 1302 Views 0 comment Print

CIT to at least record a prima facie finding that certain amount claimed by assessee as deduction in its computation of income de facto related to earning of dividend income. Thus, it was held that in the absence of any such prima facie finding, the reassessment was erroneous and no addition could be made under section 14A.

ITAT deletes addition in respect of bogus Purchases

August 27, 2021 4170 Views 0 comment Print

Supertech Forgings (India) Pvt. Ltd. Vs DCIT (ITAT Amritsar) No addition in respect of bogus Purchases can be made during the year under consideration No addition in respect of bogus Purchases can be made during the year under consideration where the purchases made from the same parties have been accepted in subsequent year by Department. […]

AO must establish a live-link between escapement of income vis-à-vis Fresh information

August 24, 2021 2283 Views 0 comment Print

ITO Vs Gujarat Storages P.Ltd. (ITAT Ahmedabad) As far as banking transactions are concerned, these details were available with the AO. This information was given in the audited accounts. Any transactions shown in the bank statement could never be construed per se as an escaped income. It is the AO who has to form his […]

Reopening for accommodation entry based on inquiries & Investigation report was valid: HC

August 18, 2021 3831 Views 0 comment Print

Sanjay Baulal Surana Vs ACIT (Gujarat High Court) 1. The function of the assessing authority at this stage is to administer the statute and what is required is a reason to believe and not to establish fact of escapement of income and therefore, looking to the scope of Section 147 as also sections 148 to […]

Section 148 Reassessment order passed in case of non-existent entity is void

August 16, 2021 5226 Views 1 comment Print

Case Name: Teleperformance Global Services Private Limited vs ACIT (Bombay High Court) Written Petition No 950 of 2020 Date of judgment/order: 09.04.2021 Related Assessment Year – 2012-13 Court: Bombay High Court The Hon’ble Bombay High Court has in case of writ petition filed by Teleperformance Global Services Private has held that assessment order passed against […]

Delhi HC stays Section 148 Proceedings in 42 cases

August 14, 2021 5055 Views 0 comment Print

SG Corporation Joint Venture Vs ITO & Ors. (Delhi High Court) 1. The respondents are restrained from continuing with the reassessment proceedings, in any manner, pursuant to the impugned notices. 2. No adjournment shall be granted on the next date of hearing. FULL TEXT OF THE HIGH COURT ORDER /JUDGEMENT On 13th July, 2021, this […]

Reassessment after 4 year invalid if assessee disclosed all material facts during original assessment

August 13, 2021 1194 Views 0 comment Print

CIT Vs Mr. John Ettimootil Samuel (Madras High Court) 1. Sets aside reassessment framed u/s 147 after expiry of four years of assessment u/s 143(3), holding that the assessee had disclosed all material facts in the original assessment qua consideration and deemed consideration u/s 50C of the Act. 2. The Tribunal was fully justified in […]

Reopening Quashed when Supplied & Recorded Reasons are Not Same & Verbatim

August 12, 2021 2610 Views 0 comment Print

Jansampark Advertising & Marketing P. Ltd. Vs ITO (ITAT Delhi) Settled position of law as held by the Hon’ble High Court in the case of Haryana Acrylic Manufacturing Co. v. Commissioner of Income Tax 308 ITR 38 [ Delhi] is that the requirement of recording the reasons, communicating the same to the assessee, enabling the […]

Assessment Based On Change of Opinion Is Void Ab Initio

August 10, 2021 1710 Views 0 comment Print

SJM International Ltd. Vs DCIT (ITAT Delhi) The conclusion of the Assessing Officer at the end of the reasons recorded as noted above is contradictory. In the first two lines, the Assessing Officer has recorded the finding that the sum of Rs.2,35,00,000/- has escaped assessment but in the last two lines, he has recorded that […]

ITAT Quashes Reassessment on Multiplicity of Errors In Reasons

August 9, 2021 1488 Views 0 comment Print

Lakhmi Chand Tejoo Mal Vs ACIT (ITAT Delhi) MULTIPLICITY OF ERRORS IN REASONS MAKE REASSESSMENT VOID  The ld. counsel for the assessee vehemently stated that 11 entries have been shown in the information and it can be seen that there are repetition of same entries/amounts and the Assessing Officer has, in fact, at para -6 […]

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