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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 876 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 2850 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


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 69 Views 0 comment Print

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 102 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 117 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 117 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


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 5886 Views 0 comment Print


No more interactions with tax officials! I-T Dept goes online with scrutiny work!

January 24, 2020 27552 Views 3 comments Print

CBDT has issued instruction dated 12th February 2018 to conduct assessment proceedings in scrutiny cases electronically, saying that except for search-related assessments, proceedings in other pending scrutiny assessment cases shall be conducted only through the E-proceeding functionality in ITBA/e-filing.

Importance of Notice in Income Tax Reassessment Proceedings

January 22, 2020 1860 Views 0 comment Print

Many times in Reassessment proceedings very little importance & attention is paid to the timing of issue of notice under section 143(2). Section 143 of Income Tax Act is about Assessment, subsection 2 of section 143 talks about issue of notice in cases where return of income has been filed within the time limits specified […]

Income Escaping Assessment Under Section 147/148 of Income Tax Act

January 21, 2020 51768 Views 3 comments Print

Section 148 stands for reassessment or income escaping assessment. Nowadays income tax department is scrutinizing more returns under Section 148 of the Income Tax Act. So we are here to discuss about section 148 of the Income Tax Act, 1961. Article explains Time limit for issuance of notice u/s 148, Issuance of show cause notice […]

Reopening Based on change of opinion and in absence of any adverse tangible material was invalid

January 16, 2020 1005 Views 0 comment Print

In such cases, assessments can be reopened only if an income assessable to tax has escaped on account of failure of the assessee to disclose all the material facts fully and truly. In other words, the AO has to demonstrate that income of the assessee has escaped assessment on account of its failure to disclose all material facts of the assessments in its income fully and truly.

Mere Outstanding loan in books cannot be reason for reopening of assessment

January 15, 2020 939 Views 0 comment Print

In the given case, the Petitioner who is a regular income tax assessee filed her return of income for the AY 2011-12. The Assessing Officer issued under section 133(6) of the Act, called for certain information from the assessee.

Section 147: Mere ‘Yes’ on approval not amounts to due application of mind

January 14, 2020 2265 Views 0 comment Print

Approval given by approving authority for reopening of assessment u/s 147 of the Income Tax Act, 1961 was without due application of mind and in mechanical manner – reassessment should be quashed.

Reopening of Assessment after 4 years only if some new Tangible material

January 13, 2020 2052 Views 0 comment Print

Arun Munshaw HUF Vs ITO (Gujarat High Court) Thus, having regard to the position of law and the materials emerging from the record of the case, it cannot be said that there was no full and true disclosure at the end of the assessee of the material facts. In such circumstances, it could be said […]

Mere participation in section 147 proceedings not confers jurisdiction upon AO

January 11, 2020 2805 Views 0 comment Print

Mere participation in proceedings or acquiescence would not confer jurisdiction upon AO who otherwise was not the AO of assessee, therefore, notice issued under section 148 was quashed and since  reopening was quashed,  subsequent orders passed on account of such reopening were also quashed.

Jurisdiction Free Assessment under Income Tax Act, 1961

January 8, 2020 17922 Views 1 comment Print

This article is covering in depth knowledge of various types of Jurisdictions, Various types of Assessments under Income Tax Act, 1961 and details of new system i.e. Jurisdiction-Free Assessment which was introduced from 2016. Jurisdiction is prescribed under Section 124 of the Income-tax Act, 1961 and assessment includes Summary assessment under section 143(1), Scrutiny assessment […]

Section 147 Reassessment justified for Cash Deposit in Bank but not disclosed in ROI

January 7, 2020 2652 Views 0 comment Print

The issue under consideration is whether the re-opening of assessement u/s 147 is justified in law?

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