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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 93 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 108 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 261 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


Reassessment after 4 year invalid if assessee disclosed all material facts during original assessment

August 13, 2021 1218 Views 0 comment Print

CIT Vs Mr. John Ettimootil Samuel (Madras High Court) 1. Sets aside reassessment framed u/s 147 after expiry of four years of assessment u/s 143(3), holding that the assessee had disclosed all material facts in the original assessment qua consideration and deemed consideration u/s 50C of the Act. 2. The Tribunal was fully justified in […]

Reopening Quashed when Supplied & Recorded Reasons are Not Same & Verbatim

August 12, 2021 2652 Views 0 comment Print

Jansampark Advertising & Marketing P. Ltd. Vs ITO (ITAT Delhi) Settled position of law as held by the Hon’ble High Court in the case of Haryana Acrylic Manufacturing Co. v. Commissioner of Income Tax 308 ITR 38 [ Delhi] is that the requirement of recording the reasons, communicating the same to the assessee, enabling the […]

Assessment Based On Change of Opinion Is Void Ab Initio

August 10, 2021 1806 Views 0 comment Print

SJM International Ltd. Vs DCIT (ITAT Delhi) The conclusion of the Assessing Officer at the end of the reasons recorded as noted above is contradictory. In the first two lines, the Assessing Officer has recorded the finding that the sum of Rs.2,35,00,000/- has escaped assessment but in the last two lines, he has recorded that […]

ITAT Quashes Reassessment on Multiplicity of Errors In Reasons

August 9, 2021 1521 Views 0 comment Print

Lakhmi Chand Tejoo Mal Vs ACIT (ITAT Delhi) MULTIPLICITY OF ERRORS IN REASONS MAKE REASSESSMENT VOID  The ld. counsel for the assessee vehemently stated that 11 entries have been shown in the information and it can be seen that there are repetition of same entries/amounts and the Assessing Officer has, in fact, at para -6 […]

Reasons Based on Material Already Available on Record Invalidates Reopening

August 8, 2021 2358 Views 0 comment Print

DCIT Vs Paveljeet Singh Ruppal (ITAT Delhi) The Assessing Officer has to demonstrate from the records that there has been a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. Here in this case, the assessee has duly disclosed the factum of total secured loan, total […]

Lack of fresh tangible material invalidates reopening when details already given in regular assessment

August 8, 2021 1761 Views 0 comment Print

ACIT Vs Sahyog Infrastructure Pvt. Ltd (ITAT Delhi) Based on the above reasons recorded, notice under Section 148 of the act was issued to the assessee on 25th of June, 2013. From the above reasons recorded it is evident that all these documents were available with the ld. Assessing Officer at the time of making […]

No section 263 revision could be made for order of reassessment

August 6, 2021 7566 Views 0 comment Print

Any order of the subordinate authority which could have been considered as erroneous and prejudicial to the interest of revenue in allowing assessee’s claim of deduction under section 80IA, either due to lack of enquiry or otherwise, was the original assessment order passed under section 143(3) r.w.s. 144C and not the re-assessment order. PCIT had proceeded to revise the assessment order passed under section 143(3) r.w.s. 147 to get over the hurdle of limitation which was impermissible.

Assessment order valid despite initial section 147 notices in wrong name if revenue identifies & corrects the mistake

August 1, 2021 4359 Views 0 comment Print

Principal Officer, M/s. Vedanta Limited Vs DCIT (Madras High Court) As far as the present Writ Petition is concerned, admittedly, the notice under Section 148 was issued in a wrong name. However, close reading of the name of the Company would reveal that the first word ‘Sesa’ is not alien to the petitioner Company and […]

Section 147: Revenue to prove failure of Assessee in Full & True Disclose of All Material Facts

August 1, 2021 2883 Views 0 comment Print

PCIT Vs Superior Films Private Limited (Delhi High Court) When the assessee has filed a return u/s 139 of the Act or in response to sections 142(1) or 148 of the I.T.Act and when an assessment order u/s 143(3) or u /s 147 of the Act has already been passed then the assessee enjoys statutory […]

Reopening assessment under Section 148 without recording reasons is bad in law

July 29, 2021 3693 Views 0 comment Print

In present facts of the case, it was observed that in the absence of  reasons, the jurisdiction assumed under section 148 of the Act to reopen a completed assessment is clearly void ab initio and consequently, assessment order is bad in law.

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