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Section 147

Latest Articles


Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 6573 Views 0 comment Print

Recent Judgements of Supreme Court on Income Tax Issues

Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....

January 22, 2024 8358 Views 1 comment Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...

December 10, 2023 19590 Views 7 comments Print


Latest News


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 6936 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 12900 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 41382 Views 2 comments Print

Notices for assessment/reassessment of income of old cases

Income Tax : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...

August 3, 2018 1893 Views 0 comment Print

No Reopening of Assessment to be made on Audit Objections: Committee Recommends

Income Tax : One of the key sources of dispute is the existing arrangement for follow up on audit objections by Internal Audit Party and the Re...

January 20, 2016 6657 Views 0 comment Print


Latest Judiciary


Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 63 Views 0 comment Print

Reassessment cannot be based solely on reevaluating existing facts without new substantive material

Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...

July 17, 2024 60 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 126 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 261 Views 0 comment Print

Non-Filing of GST Return by Supplier – Assessment Reopening Validity- ITAT Mumbai Order

Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...

July 17, 2024 738 Views 0 comment Print


Latest Notifications


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 8571 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 3063 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 5337 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 2934 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 14292 Views 1 comment Print


Higher rate of tax in case of foreign company is not in violation of non-discrimination clause

September 15, 2023 468 Views 0 comment Print

ITAT Mumbai held that rate of tax in case of foreign company is higher than rate of tax in case of domestic company and as per the Explanation in the Section 90, inserted in the IT Act with retrospective effect from 01-04-1962 the should not be regarded as violation of nondiscrimination clause.

Payment of guarantee fees to holding company for loan advanced to third party is deductible u/s. 37

September 15, 2023 594 Views 0 comment Print

ITAT Mumbai held that guarantee fees paid to holding company for loan advanced by assessee to third party is commercial/ business expediency and hence allowable as deduction under Section 37 of the Income Tax Act.

Payment of guarantee fee to Gujarat Government is revenue expenditure

September 15, 2023 273 Views 0 comment Print

ITAT Ahmedabad held that payment of guarantee fee to the Govt. of Gujarat in consideration of guarantee issued by it for repayment of unsecured loan is revenue expenditure.

Give chance to Assessee to establish non-receipt of statutory notices: ITAT

September 14, 2023 747 Views 0 comment Print

An in-depth analysis of the ITAT Delhi’s order in the case Poonam C/o Sanjeev Anand vs ITO, focusing on the significance of the ruling that assessees should be given a chance to establish non-receipt of statutory notices.

ITAT Quashes Reassessment on grounds of being based on vague & non-descript reasons

September 14, 2023 681 Views 0 comment Print

An in-depth analysis of ITAT Delhi’s verdict in the case of Captive Commerce Pvt. Ltd. Vs ACIT. The tribunal quashes the reassessment order under Section 148 of Income Tax Act for vague reasons.

Fund utilized more than prescribed limit for achieving objective allowable U/s. 11

September 13, 2023 570 Views 0 comment Print

Himachal Pradesh High Court held that exemption u/s 11 of the Income Tax Act duly entitled even if Funds Pending Utilization was more than the prescribed limit as proved that funds were utilized for the purpose of achieving its objective.

Reopening of assessment without any fresh tangible material unsustainable

September 13, 2023 924 Views 0 comment Print

ITAT Ahmedabad held that reopening of assessment under section 147 of the Income Tax Act initiated on a mere change of opinion without any fresh tangible material unsustainable in law.

ITAT Grants Section 80IA Deduction for Port Charges, Favors Liberal Interpretation

September 12, 2023 519 Views 0 comment Print

A comprehensive analysis of ITAT Mumbai case DCIT Vs PNP Maritime Services Pvt. Ltd. Focusing on Section 80IA deduction on port charges and its implications

Date of handing over of possession of new property relevant for deduction u/s. 54

September 11, 2023 987 Views 0 comment Print

ITAT Delhi held that deduction under section 54 of the Income Tax Act is allowable based on handing over of possession and not based on payment of consideration. Date of handing over of possession of new property is relevant for deduction u/s. 54.

Change of opinion impermissible under the grab of reopening u/s 147

September 9, 2023 1410 Views 0 comment Print

ITAT Mumbai held that change of opinion is not permissible under the garb of reopening of assessment under section 147/148 of the Income Tax Act.

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