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Section 147

Latest Articles


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 93771 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


Mere Client Code Modification Allegation Did Not Justify Taxing Entire Commodity Purchases

Income Tax : Tribunal held that allegations relating to client code modification did not justify adding the entire purchase value under Section...

June 25, 2026 42 Views 0 comment Print

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 105 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 105 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 117 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


No reassessment in absence of failure on part of assessee to fully & truly disclose all material facts

January 3, 2022 2145 Views 0 comment Print

District Co-operative Central Bank Ltd. Vs ACIT (ITAT Bengalore) Conclusion: Reassessment beyond four years was not valid in the absence of failure on part of assessee to fully and truly disclose all material facts necessary for assessment. Held: Assessee claimed deduction of Rs.3,50,00,000/- u/s 36(1)(viia). However, assessee debited only Rs.3,00,00,000/- to the profit and loss […]

CIT sanction without application of judicious mind is invalid- section 151

December 22, 2021 4233 Views 0 comment Print

Since in the present case, the sanction was accorded by the ld. CIT in a purely mechanical manner without application of judicious mind, therefore, the sanction so accorded cannot be held to be a proper and valid sanction within the meaning of Section 151 of the Act

HC quashes Notice for Reopening of Assessment as reason for reopening not state that there was any failure on the part of petitioner

December 17, 2021 1959 Views 0 comment Print

Coca-Cola India Private Limited Vs DCIT (Bombay High Court) Revenue relied upon a Bombay HC judgment in Crompton Greaves Ltd. V/s. ACIT to submit that even if the reason for reopening does not specifically state that there was any failure on the part of petitioner to disclose fully and truly all material facts necessary for […]

Reopening of Assessment Not Permissible for Change of Opinion

December 15, 2021 1731 Views 0 comment Print

Skoda Auto Volkswagen India Private Limited Vs ACIT (Bombay High Court) Petitioner had in its annual report mentioned about the technical know how fee, royalty and technical assistance fee that it had paid to Skoda Auto a.s. and Volks Wagen AG. Petitioner had also filed Form 3CEB in which it had disclosed about details and […]

Addition based on mere Third Party statement without granting Cross-Examination deleted

December 13, 2021 8871 Views 0 comment Print

Vijayshree Food Products P. Ltd. Vs ACIT (ITAT Delhi) The reopening has been challenged by the assessee stating that initiation of proceedings u/s 147 of the income tax act is solely on the basis of the unverified, on rectified, unsubstantiated and unconfirmed statement of Mr Malu. It is further the claim of the assessee that […]

Bogus LTCG- HC upheld Reassessment notice after expiry of 4 Years

December 10, 2021 2529 Views 0 comment Print

Kaushaliya Sampatlal Dudani Vs ITO (Gujarat High Court) A bare perusal of the reasons recorded and further clarification of the information made by the revenue by way of affidavit in reply would make it clear that, the company Tuni Textile Ltd., was used in providing bogus accommodation entries of long term capital gain by certain […]

Mere disclosure of bogus transaction not sufficient, reopening of assessment sustainable

December 9, 2021 4977 Views 0 comment Print

After framing of the assessment made under Section 143(3) of the Act, tangible material came into the hands of the AO through the investigation wing and upon perusal of the same, he made independent inquiries and applied his mind and upon due satisfaction, he formed an opinion that, the income has escaped assessment.

HC Quashes reopening notice issued merely based on change of opinion

December 5, 2021 1527 Views 0 comment Print

Rama Devi Sabat Vs DCIT (Orissa High Court) Contending that the initiation of the reassessment proceedings was based merely on a change of opinion, the present petition has been filed. A perusal of the reasons mentioned above for reopening of the assessment reveals that there was no new material available with department. It is also […]

Is it be Possible to Re-Open Assessment only Because of Change of Opinion?

December 5, 2021 2112 Views 0 comment Print

We know that provisions of sections 147 to 151 of the Income Tax Act, 1961 deal with Reassessment of and escaped assessment of income of an assessee. Income Tax Officer under these provisions reassess by reopening the cases assessed earlier on the believe that incomes or profits or gains chargeable to income tax has escaped […]

PCIT can exercise section 263 powers only in respect of original assessment

November 28, 2021 6438 Views 0 comment Print

Royal Western India Turf Club Vs PCIT (ITAT Mumbai) Undisputedly, the original assessment in case of the assessee was completed under section 143(3) of the Act on 06-02-2014. Subsequently, the assessment was reopened under section 147 of the Act and notice under section 148 of the Act was issued to the assessee on 26-03-2018. The […]

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