Follow Us:

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 513 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 876 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 2853 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 18264 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


Reopening of Assessment Upheld Due to Form 26AS Showing Undisclosed Contract Income

Income Tax : The Tribunal upheld reopening under Section 147 as Form 26AS reflected substantial contract receipts despite no return being filed...

May 3, 2026 102 Views 0 comment Print

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 108 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 120 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 117 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 96 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 5745 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 5886 Views 0 comment Print


s. 292B cannot save Assessment order passed without Notice u/s 143(2)

April 19, 2018 1950 Views 0 comment Print

ITO Vs. Sh. Neeraj Goel (ITAT Delhi) IT(A) has rightly held that the assumption of jurisdiction to frame an assessment or non assumption of jurisdiction to frame an assessment goes to the root of the judicial act of framing an assessment order and in the event of non assumption of jurisdiction u/s. 143(2) of the […]

Non issue of notice U/s. 143(2) invalidates reassessment

April 18, 2018 4089 Views 0 comment Print

A.M. Muthiah & Anr. Vs DCIT (ITAT Mumbai) Issuance of notice under section 143(2) is mandatory, and absence thereof invalidates even a reassessment made in pursuance to section 148 and reliance placed by AO on section 292BB was misplaced.

Deeming fiction U/s. 292BB not applicable on failure to issue notice U/s. 143(2) within specified period

April 14, 2018 1272 Views 0 comment Print

This appeal is filed by the assessee against the order of the Learned Commissioner (Appeals)–21, Mumbai dated 28-3-2016 for the assessment year 2011-12. The assessee in its appeal raised several grounds of appeal both on validity of issue of service of notice under section 143(2)/148 of the Act as well on merits of the disallowances.

Reopening of assessment maintainable on reasons recorded for reopening

April 14, 2018 3114 Views 0 comment Print

This petition under Article 226 of the Constitution of India is directed against the notice dated 31-3-2017 issued by the respondent-Income Tax Officer under section 148 of the Income Tax Act, 1961 (hereinafter referred to as the Act), seeking to reopen the assessment of the petitioner for assessment year 2010-11.

Reopening after 4 years with approval of DIT instead of JCIT is invalid

April 11, 2018 1923 Views 0 comment Print

Reopening of assessment of A.Y. 2005-06 after expiry of four years without obtaining approval of an officer of the rank of Joint Commissioner was bad in law and even if such approval had been granted, by the officer superior i.e., the DIT, it would not cure the defect.

Reassessment merely on DIT (Investigation) information is bad under law

April 10, 2018 4008 Views 0 comment Print

Reasons recorded by AO to reopen assessment merely on basis of information from DIT(Inv.) without independently applying his own mind could not be said to be reason to believe that income had escaped assessment hence, reopening was bad in law.

No penalty on income on which tax been paid before notice U/s. 148 & disclosed later

April 8, 2018 16404 Views 0 comment Print

Prabhjit Singh Sidhu Vs. Asst. DIT (International Taxation) (ITAT Chandigarh) The facts before us also demonstrate that the disclosure in the return of income filed under section 148 of the Act was voluntary and before detection of the same by the Revenue. The payment of taxes on the said income two months prior to issue […]

Reopening based on mere Tax Audit report Filed during Scrutiny Proceedings is Invalid

March 19, 2018 2514 Views 0 comment Print

Mahanadi Coalfields Ltd. Vs. ACIT, (ITAT Cuttack) In the present case found that thee Assessing Officer has initiated reassessment proceedings on the same facts which were available before him at the time of making assessment u/s.143(3) of the Act and no new tangible material has come on the basis of which it could be said […]

Assessment u/s. 153A cannot be framed if no incriminating material found during search

March 7, 2018 1833 Views 0 comment Print

Asstt Vs Maruti Clean Coal & Power Ltd. (ITAT Raipur) There is no dispute that no incriminating material has been found at the time of search and therefore it is now settled proposition of law that no assessment u/s. 153A of the Act can be framed in the absence of any incriminating material found at the […]

In absence of issue of notice U/s. 143(2) assessment U/s. 143(3) r.w. section 147 was invalid and void ab initio

March 4, 2018 6450 Views 1 comment Print

Shri Ramesh Salecha HUF Vs. ITO (ITAT Mumbai) Revenue could not produce before us any evidence to show that notice under sections 143(2) has been issued or served to the assessee the re-assessment made under sections 143(3) read with section 147 is void ab-initio in view of the above decisions of the Honorable Allahabad High Court in […]

Search Post by Date
May 2026
M T W T F S S
 123
45678910
11121314151617
18192021222324
25262728293031