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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 18258 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 75 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 105 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 99 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 90 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 5742 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


Wrong Approval u/s 151(ii) Vitiates Reassessment: ITAT Bangalore Quashes 147 Order & Entire Proceedings (AY 2016-17)

February 12, 2026 207 Views 0 comment Print

The Tribunal held that treating part of the disclosed sale proceeds as unexplained cash credit amounts to double taxation. It directed deletion of the addition to the extent linked to the accepted sale consideration.

ITAT Bangalore allows appeal — Delay of 298 days condoned; Gratuity & Commuted Pension held exempt u/s 10(10) & 10(10A); 115BBE & 69A additions deleted

February 12, 2026 216 Views 0 comment Print

The Tribunal condoned a 298-day delay in filing appeal, holding that substantial justice must prevail over technicalities. It deleted additions on exempt gratuity and commuted pension, ruling they cannot be taxed as salary.

ITAT Bangalore Quashed Reassessment for Sanction by wrong authority After 3-Year Limit

February 12, 2026 597 Views 0 comment Print

The Tribunal held that reassessment initiated after three years required approval from the higher authority specified under the amended section 151. Since sanction was obtained from an incorrect authority, the entire proceeding was invalidated.

Reassessment Quashed as Section 148 Notice Issued After Six-Year Limitation

February 12, 2026 1386 Views 0 comment Print

Applying Supreme Court precedent, the Tribunal held that no notice could be issued once the six-year period under the old regime had expired. The reassessment order was therefore annulled.

Reassessment Invalid as Approval Taken from Wrong Authority Beyond Three-Year Limit: Delhi HC

February 11, 2026 639 Views 0 comment Print

The Delhi High Court held that reassessment beyond three years requires approval under Section 151(ii). Notices issued with approval from the wrong authority were set aside.

Madras HC Upheld Reassessment but Order Set Aside for Lack of Discussion on Penny Stock Addition

February 11, 2026 2703 Views 0 comment Print

The Court held that notice under Section 148A(b) was valid despite search-related arguments. However, the assessment was set aside due to absence of proper reasoning on denial of Section 10(38) exemption for long-term capital gains.

Section 54F Deduction Based on Actual Sale Consideration, Not Deemed Value: ITAT Raipur

February 11, 2026 1194 Views 0 comment Print

The Tribunal held that deduction under Section 54F must be computed with reference to actual sale consideration received, not the deemed value under Section 50C. The matter was remanded for recomputation of LTCG accordingly.

Notices u/s 148 issued by JAO was invalid due to mandatory faceless procedure u/s 151A

February 11, 2026 6015 Views 1 comment Print

Once the Central Government notified the Faceless Scheme for reassessment (effective March 29, 2022), the JAO was effectively divested of the power to issue notices under Section 148. The issuance of a notice by a JAO instead of the National Faceless Assessment Centre (NFAC) was a jurisdictional error that could not be cured.

Wrong Email Leads to Missed Notices; ITAT Delhi Orders Fresh Opportunity Before AO

February 10, 2026 690 Views 0 comment Print

The ITAT held that an assessment and appellate order passed without effective participation, allegedly due to notices sent to a wrong email address, must be set aside and remanded for fresh adjudication.

ITAT Remands Case After Appeal Dismissed for Delay, Gives One Chance to Explain Cash Deposits

February 10, 2026 393 Views 0 comment Print

The Tribunal restored the matter after holding that dismissal of the appeal without giving a chance to explain delay and cash deposits was not justified.

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