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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


Merely reason to believe not sufficient to reopen assessments beyond 4 year period

June 12, 2020 1872 Views 0 comment Print

ITAT Kolkata ruling on Amrabathi Investra (P) Ltd. Vs ITO case. Assessment reopened u/s 147. Read full judgment details and outcome.

No capital gain tax on land transfer to co-op society formed by flat purchasers

June 12, 2020 8571 Views 1 comment Print

Whether the AO is correct in considering that the capital gain will arise in the year when the land is transferred to the co-operative society formed by the flat purchasers and not when flats are sold?

Non-rejection of explanation in Assessment Order amounts to acceptance: SC

June 8, 2020 3216 Views 1 comment Print

The non-rejection of the explanation in the Assessment Order would amount to the Assessing Officer accepting the view of the assessee, thus taking a view/forming an opinion.

Reassessment merely on Investigation officer report is unsustainable

June 7, 2020 1704 Views 0 comment Print

Ashapura Minichem Limited Vs DCIT (ITAT Mumbai) The issue under consideration is whether the re-opening of assessment u/s 147 is justified in law? The assessee before us is a listed public limited company engaged in the business of mining bauxite and selling the same in domestic as well as international market. In the present case […]

Dealing with reassessment under Income Tax Act, 1961

June 4, 2020 9126 Views 0 comment Print

As per section 2(8) of the Income Tax Act, 1961, the term assessment includes re-assessment. Meaning of income escaping assessment: As per the provisions contained in section 147 of the Income Tax Act, 1961, if the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, […]

Mere bald assertions by AO in reasons for reopening would confer valid jurisdiction to AO to Reopen?

June 3, 2020 1785 Views 0 comment Print

Each aspect of Section 147 has been a subject matter of careful scrutiny by the court of law. One such main issue is with respect to the validity of the assumption of jurisdiction by the AO to reopen the assessment beyond four years, merely by making a Bald Assertion in the reasons as to the failure of the Assessee to disclose fully and truly all the material facts. The author has made an analysis veracity of such practice with the help of available judicial pronouncements

MSBTE is ‘State’ under Indian Constitution & Exempt from Income Tax

June 3, 2020 2436 Views 0 comment Print

The issue under consideration is whether CIT(A) is correct in holding that the appellant is not a state under Article 289 of the Constitution of India and therefore, liable to tax under the Income Tax Act?

Assessee can claim Section 54F deduction during Section 147 Proceedings

June 2, 2020 5097 Views 0 comment Print

Whether AO is correct in rejecting the claim of assessee regarding the deduction u/s 54F, which was made first time during Reassessment Proceedings?

No section 147 notice based on material already presented during section 143(3) assessment

May 30, 2020 2163 Views 0 comment Print

The issue under consideration is whether A.O. is correct in issuing Notice under section 147 for re-opening of assessment irrespective of the fact that the material on which he relied is already present in front of him at the time of assessment u/s 143(3)?

No reassessment after 4 years in case there was no disclosure failure on the part of assessee

May 29, 2020 3738 Views 0 comment Print

AO was not justified in reopening of assessment after four years as on an independent application of mind and on thorough consideration of material aspects and legal position,there was no failure on the part of assessee.

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