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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 507 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 873 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 2841 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 18258 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


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 63 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 105 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 96 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 90 Views 0 comment Print

Reassessment Notice Time-Barred as Issued Beyond Limitation Period: Karnataka HC

Income Tax : The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after t...

May 1, 2026 447 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 5742 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 5880 Views 0 comment Print


Low NP Isn’t “Reason to Believe” – Reopening Quashed & Estimation Dies with It

February 7, 2026 162 Views 0 comment Print

The tribunal held that merely declaring a low net profit rate cannot justify reopening under Section 147. A valid reassessment requires tangible material and a live nexus with income escapement.

Reopening Beyond limitation – Mechanical Approval Fatal – Entire Batch Collapses

February 7, 2026 549 Views 0 comment Print

The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.

Political Donation Deduction Allowed Due to Lack of Assessee-Specific Evidence

February 7, 2026 24825 Views 0 comment Print

The Tribunal upheld deletion of disallowance where the tax authority failed to produce direct evidence linking the taxpayer to any refund of alleged bogus political donations.

Rajeev Bansal Strikes Again – Time-Barred Reopening & Entire Capital-Gain Addition Quashed

February 7, 2026 1713 Views 0 comment Print

Since the reassessment notice was barred by limitation, the tribunal did not examine capital gains issues on merits. The ruling confirms that jurisdictional defects override substantive tax disputes.

Reopening Quashed for Non-Application of Mind & Wrong Sanction

February 7, 2026 1239 Views 0 comment Print

The tribunal ruled that reassessment beyond four years is barred when reasons do not allege failure to disclose material facts. Mere suspicion of escaped income is insufficient to override the statutory limitation.

SC Quashed Unreasoned Bail Order in Murder Case for Non-Application of Mind

February 7, 2026 216 Views 0 comment Print

The Supreme Court held that bail was wrongly granted without considering medical and eyewitness evidence. The ruling underscores that serious offences require careful judicial scrutiny before granting bail.

₹3.40 Crore Housing Project Deduction Restored After Reopening Beyond 4 Years Set Aside

February 6, 2026 300 Views 0 comment Print

The ITAT held that reopening an assessment after four years without any new tangible material is invalid. A reassessment based merely on re-examining earlier facts was struck down as a change of opinion.

Search Assessment – Telescoping Upheld, No Double Taxation & U/s 234A Interest Curtailed

February 6, 2026 291 Views 0 comment Print

The tribunal held that amounts already disclosed and taxed as accommodated receipts cannot be taxed again under another head. Separate additions were deleted as they resulted in impermissible double taxation.

Re-assessment U/s 147 Quashed as Time-Barred — Stay Period Ends on Date of Vacation, Not Communication

February 6, 2026 369 Views 0 comment Print

The issue was whether reassessment completed after a court stay complied with statutory timelines. The Tribunal held that limitation resumes from the date the stay is vacated, rendering the reassessment time-barred.

Borrowed Satisfaction from Insight Portal Invalid; Re-opening Section 68 Addition Quashed

February 6, 2026 519 Views 0 comment Print

The issue was whether reopening based only on portal information is valid. The Tribunal held that absence of independent inquiry and tangible material vitiates reassessment and nullifies the addition.

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