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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 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


Assessment cannot be Reopened if Assessee disclosed fully & Truly All Material Facts during Original Assessment

August 12, 2020 1758 Views 0 comment Print

The issue under consideration is whether the AO is correct in re-opening of the assessment under section 147 even though the assessee has disclose fully and truly all the material facts during original assessment?

Reassessment not sustainable when reasons for initiation of proceedings Seized to Survive

August 11, 2020 1182 Views 0 comment Print

Aince the AO has accepted the returned income for which reasons were recorded, therefore, for making any other addition, he should have issued fresh notice

Assessment reopening based on Wrong Appreciation of Facts is unsustainable

August 10, 2020 1572 Views 0 comment Print

The issue under consideration is whether the re-opening of assessment u/s 147 on the basis of wrong appreciation of facts can be sustained in law?

Issues in Respect of Reopening of Assessment

August 10, 2020 5706 Views 0 comment Print

Mr. Jay Kishor Mishra, IRS (IT: 1993) CIT (DR)(ITAT)-4, Delhi jkmishrairs@gmail.com Mr. Jay Kishor Mishra is an officer of the 1993 batch of the Indian Revenue Service. He is a Graduate in Economics and Post Graduate in Sanskrit. He is an LLB and also holds Post Graduate Diploma in Management. Ms Sushama Singh, IRS (IT: […]

No TDS on payments to NRI for Purchase of Raw Materials

July 31, 2020 4287 Views 0 comment Print

The issue under consideration is whether the provisions of deduction of tax at source (TDS) would be applicable in case of payments made to non-resident Indian for the purchase of raw materials?

Reopening after 4 years in absence of failure of Assessee to disclose fully & truly all material facts necessary for assessment is invalid

July 30, 2020 1557 Views 0 comment Print

ACIT Vs Shiv Vegpro Pvt. Ltd. (ITAT Jaipur) Reopening after 4 years in absence of failure of Assessee to disclose fully & truly all material facts necessary for assessment is invalid AO has even not mentioned as on what account or transactions the assessee has taken the accommodation entry from Shree Ram Trading Co. It […]

Bogus Purchase: Addition on peal credit basis for Low Margin & Low Vat Rate Items unjustified

July 28, 2020 933 Views 0 comment Print

The issue under consideration is whether the CIT(A) is correct in confirming addition u/s 69C of the Act on account of unexplained purchases made during the year, calculated on the basis of peak credit?

Assessment cannot be Reopened based on data already disclosed in scrutiny assessment

July 28, 2020 3375 Views 0 comment Print

Gateway Leasing Pvt. Ltd. Vs ACIT (Bombay High Court) The issue under consideration is whether the re-opening of the assessment u/s 147 is justified in law? In the present case, after referring to the information received following search and seizure action carried out in the premises of Shri Naresh Jain, it was stated that information […]

AO recorded reasons on same returned income- Reassessment Invalid

July 25, 2020 2001 Views 0 comment Print

AO recording reasons on same returned income considering escaped assessment but making various other additions of other than accepted returned income declared invalid and deleted in light of Explanation 3 and held issuance of fresh notice u/s 148 on other issues is mandatory.

HC denies relief in section 147 proceedings for not replying notice for 6 Months

July 24, 2020 1491 Views 0 comment Print

he Supreme Court in GKN Driveshafts (India Ltd.) v. Income Tax Officer 259 ITR 19 (SC) has clarified that when a notice under Section 148 of the Income Tax Act is issued, the proper course of action for the notice is to file a return and if he so desire, to seek reasons for issuing notices.

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