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Section 147

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FAQs on Assessments under Income-tax Law

Income Tax : Learn how different types of income tax assessments are conducted under the Income-tax Act. The FAQs explain assessment procedures...

June 24, 2026 93765 Views 7 comments Print

FAQs on Maintenance of books of accounts under Income Tax Act, 1961

Income Tax : This guide explains who is required to maintain books of account under Section 44AA based on business, profession, turnover, and i...

June 23, 2026 6222 Views 0 comment Print

Assessments under Income-Tax Act, 1961

Income Tax : This guide explains the various assessments under the Income-tax Act, including summary assessment, scrutiny assessment, best judg...

June 17, 2026 434525 Views 13 comments Print

Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...

May 13, 2026 579 Views 0 comment Print

CIT(A) cannot enhance income on issues not examined by AO: ITAT Mumbai

Income Tax : The Tribunal held that CIT(A) cannot enhance income under Section 251 on matters not considered by the Assessing Officer during as...

May 10, 2026 741 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 2430 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 4533 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 7512 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 13386 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 42888 Views 2 comments Print


Latest Judiciary


ITAT Mumbai Quashes Reassessment Orders Due to Time-Barred Section 148 Notices

Income Tax : The ITAT held that reassessment notices issued after the surviving limitation period prescribed by the Supreme Court were invalid....

June 25, 2026 99 Views 0 comment Print

Gujarat HC Sets Aside Reopening as High-Value Bank Credits Alone Cannot Justify Reassessment

Income Tax : The Gujarat High Court held that reassessment cannot be sustained merely because of high-value bank transactions without evidence ...

June 25, 2026 102 Views 0 comment Print

ITAT Rejects Bogus LTCG Addition as No Independent Enquiry Was Conducted

Income Tax : ITAT Ahmedabad held that an addition under Section 68 cannot be sustained solely on information received from the Investigation Wi...

June 25, 2026 66 Views 0 comment Print

ITAT Remands Property Sale Gain Addition as Purchase Cost Was Not Considered

Income Tax : The ITAT Hyderabad held that the entire sale consideration could not be assessed as short-term capital gains without examining the...

June 25, 2026 114 Views 0 comment Print

ITAT Quashes Reassessment as Section 151 Approval Was Not Obtained from Competent Authority

Income Tax : ITAT Pune held that the reassessment proceedings were invalid because the notice under Section 148 was approved by the Principal C...

June 24, 2026 264 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 5928 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 906 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 10392 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 5991 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 5967 Views 0 comment Print


Reopening notice invalid in absence of any tangible material to establish escapement of income for assessment

February 28, 2022 1521 Views 0 comment Print

ACIT Vs Ravi Parkash Aggarwal (ITAT Delhi) Primarily, we find that the reasons recorded by the assessee are too sketchy and does not instill any confidence with regard to the reasons recorded for reopening. It is not even clear whether the assessee has received entries pertaining to loans or purchases. The details of the report […]

AO not entitled on change of opinion to commence reassessment proceedings

February 28, 2022 3375 Views 0 comment Print

Macrotech Developers Limited Vs ACIT (Bombay High Court) The question is whether there was a failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment of Assessment Year 2012-13. It is not the case that there is failure on the part of the assessee to make […]

AO cannot reopen an assessment even within a period of 4 years merely on the basis of a change of opinion

February 24, 2022 2079 Views 0 comment Print

Glaxosmithkline Pharmaceuticals Ltd. Vs ACIT/DCIT (Bombay High Court) Admittedly, this is a case where the notice under Section 148 of the Act has been issued after the expiry of 4 years from the end of the relevant assessment year and assessment under Section 143(3) of the Act has also been completed. Hence, proviso to Section […]

Review in the garb of reassessment is absolutely prohibited

February 23, 2022 2736 Views 0 comment Print

Tata Sons Limited Vs DCIT (Bombay High Court) This is a case where the scrutiny assessment was completed and order under section 143(3) of the Act has been passed followed by a rectification order under section 154 of the Act. Therefore Petitioner’s case has been considered at two stages, (i) When the assessment order was […]

HC surprised with reasons recorded for reopening & hoped for better reasons

February 23, 2022 2370 Views 0 comment Print

Nirmal Bang Securities Pvt Ltd Vs ACIT (Bombay High Court) In this case reasons quoted were bereft of any material as AO quoted that search information is received with regard to accommodation entry But  does not indicate what address was searched, from whom such information was received, what date the search happened, what date the […]

HC dismisses Reassessment Notice to Tata Sons Based on mere change of opinion

February 20, 2022 1194 Views 0 comment Print

Tata Sons Limited Vs DCIT (Bombay High Court) Bombay High Court find substance in the submission of Mr.Pardiwalla that the case at hand is nothing but an instance of mere change of opinion. A bare perusal of the reasons indicates that the exercise was infuenced by a mere change of opinion. To start with, it […]

Failure to issue section 143(2) notice prior to finalising reassessment order makes reassessment proceedings a nullity

February 7, 2022 7680 Views 0 comment Print

ACIT Vs P & R Infraprojects Ltd. (ITAT Delhi) A perusal of the assessment order as well as the order of the CIT(A) shows that no notice u/s 143(2) was ever issued to the assessee before completing the assessment u/s 143(3)/147. It is the submission of the ld. Counsel that it is mandatory to issue […]

Division Bench of Rajasthan HC Quashes Section 148 notices in 472 cases

January 28, 2022 3612 Views 0 comment Print

Introduction: – The Division Bench of Hon. Rajasthan High Court consisting of Chief Justice Akil kureshi and Justice Sameer Jain. in Sudesh Taneja vs. ITO DB W.P No.969/2022. Order dated 27.01.22 quashed the reassessment notices issued after 31.03.21. Earlier the Ld. Single judge of Hon. Rajasthan HC had quashed reassessment notices u/s 148 of the […]

Rajasthan HC quashes Section 148 Notice issued after 31.03.2021 in 472 Cases

January 28, 2022 13860 Views 0 comment Print

Sudesh Taneja Vs ITO (Rajasthan High Court) In the writ petitions the petitioners have challenged respective notices issued by the Assessing Officers under Section 148 of the Income Tax Act, 1961 (‘the Act’ for short) for reopening assessments for various assessment years. All these notices have been issued after 01.04.2021 and pertain to relevant period […]

HC Quashes Section 147 Assessment as reason for reopening was not sustainable

January 28, 2022 3222 Views 0 comment Print

Giraben Atulbhai Shah Vs ACIT (Gujarat High Court) The objections raised by the assessee came to be disposed of by the Assessing Officer vide his order dated 16th November 2021 stating that the assessee sold immovable property for an aggregate value of Rs.52 Lakh and the same was not offered for tax in the return […]

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