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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


Income escaping assessment | Action to be taken | AY 2013-14 to 2017-18

March 9, 2021 20715 Views 0 comment Print

Which functionality is to be used for uploading the information in respect of cases where the income escaping assessment pertains to AYs 2013-14 to 2017-18 as mentioned in Para 2(a) of the aforementioned directions issued vide F.No.414/132/2018-IT(Inv.I)(Part I) dated 5th March, 2021?

Instructions for issue of Section 148 notice for Reassessment/Reopening

March 4, 2021 49260 Views 2 comments Print

CBDT directs that following categories of cases be considered as ‘potential cases’ for taking action u/s 148 of Act by 31.03.2021 for the A.Y 2013-14 to A.Y 2017-18 by Jurisdictional Assessing Officer

Addition for unexplained cash deposit by CIT(A) justified -ITAT Delhi

March 4, 2021 4065 Views 0 comment Print

Shri Praveen Garg Vs ITO  (ITAT Delhi) There is no dispute with regard to the legal proposition that the First Appellate Authority cannot consider new source of income. However, in the present case the A.O. reopened the assessment because it was found that there were cash deposits in several Bank accounts of the assessee which […]

HC quashes Section 148 Notice issued without prior administrative approval of PCIT

March 4, 2021 2802 Views 0 comment Print

According to Mr. Mahna, the administrative approval of Principal Chief Commissioner, Income Tax was obtained by the Assistant Commissioner, Income Tax only on 30.03.2018, i.e., after the issuance of the notice under Section 148 of the Act.

No Reopening On Borrowed Satisfaction Without Bringing Tangible Material on Record

February 23, 2021 2319 Views 0 comment Print

Luxe Trading And Holding (India) Pvt. Ltd. Vs ITO (ITAT Delhi) From a perusal of the reasons, it is seen that the notice u/s. 148 of the Act has been issued mechanically without application of mind and the satisfaction by the Assessing Officer is only the borrowed satisfaction of the Investigation Wing. The Assessing Officer, […]

No Change of Opinion if facts related to deemed consideration U/s. 50C been overlooked

February 19, 2021 1215 Views 0 comment Print

Rakesh Ambalal Patel Vs ITO (ITAT Ahmedabad) We have perused the assessment order and the order of the CIT(A) as well as the materials placed on record and referred to in terms of Rule 18(6) of the Income Tax (Appellate Tribunal) Rules, 1963. On perusal, we observe that at the time of original assessment proceedings, […]

No Reopening on Borrowed Satisfaction when view was already taken by AO

February 19, 2021 1758 Views 0 comment Print

Alliance Filaments Ltd Vs ACIT (Gujarat High Court) A plain reading of the reasons recorded revels that the Assessing Officer has solely relied on the information received from the Investigation Wing- Surat. We are of the view that, the Assessing Officer has not applied his independent mind while recording the reasons that the income has […]

Reopening of assessment invalid if based on “change of opinion”

February 18, 2021 1245 Views 0 comment Print

We are of the view that the AO has re-opened the assessment on mere change of opinion, because it is the assessing officer who took a different view at the time of reopening of assessment, i.e., he has entertained an opinion that the family members should have transferred the gold to the assessee firm and then the assessee firm should have held the gold on its own account.

Section 147: AO must act based on ‘reasons to believe’ & not on ‘reasons to suspect’

February 12, 2021 5283 Views 0 comment Print

Kasapu Ramesh Babu Vs ITO (ITAT Visakhapatnam) Assessing Officer has to act on the basis of “reasons to believe” and not on “reasons to suspect”. In the instant case, the initiation of proceedings u/s 147 of the Act are based upon no evidence and/or un-corroborative material. The Assessing Officer further failed to establish the nexus […]

Mere Vague Air Information of Cash Deposit Not Sufficient to believe Escapement of Income

February 10, 2021 4224 Views 0 comment Print

Harmeet Singh Vs ITO (ITAT Delhi) At the time of hearing, Ld. Counsel of the assessee has only argued the legal ground and stated that the reopening action of the AO and confirmation thereof by the Ld. CIT(A) is in violation of mandatory jurisdictional conditions stipulated under the Act. It was further stated that the […]

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