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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 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 48 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 108 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


Claim Allowed in Original Assessment Cannot be Amenable to Provisions of Section 147/148

November 28, 2020 1224 Views 0 comment Print

The issue under consideration is whether the notice issued under section 147 for re-opening of assessment is justified in law? A claim which has been allowed in the original assessment proceedings after examination of the relevant details and facts cannot be amenable to provisions of Section 147/148 of the Act.

Enhancement by CIT(A) on an issue which were not part of reasons recorded for reopening the assessment are invalid

November 27, 2020 1722 Views 0 comment Print

Harendra Singh Vs ITO (ITAT Delhi) CIT(A) while deleting the sole foundational issue on which the re-assessment proceedings were initiated, cannot go further and examine an issue which was not even the subject matter of re-assessment proceedings Since the reopening was to verify the purchase transaction and since the said transaction never took place and, […]

Re-Opening of Assessment u/s 147 Merely Relying upon Investigation Report Not Justified in Law

November 27, 2020 1653 Views 0 comment Print

Eminent Computers Pvt. Ltd. Vs ITO (ITAT Delhi) The issue under consideration is whether the re-opening of assessment u/s 147 merely relying upon investigation report is justified in law? ITAT states that the return of income filed by the assessee has also been analyzed with reference to the information received from the Investigation Wing and […]

Reassessment based on Invalid Facts with no Application of Mind is Invalid

November 25, 2020 1755 Views 0 comment Print

M/s Aash Trading Company Pvt. Ltd. Vs ITO (ITAT Delhi) We find that AO in the reasons recorded has mentioned that Rs. 75 lacs on account of accommodation entry has been escaped, however, he had issued noticed u/s. 148 of the Act to the assesee. In response to the same, assessee filed the objection which […]

Complemented Assessment cannot be reopened U/s. 147/148 on Borrowed Satisfaction

November 12, 2020 11889 Views 0 comment Print

Hitesh Ashok Vaswani Vs DCIT (ITAT Ahmedabad) The power to reopen a completed assessment under Section 147 of the Act has been bestowed on the Assessing Officer, if he has reason to believe that any income chargeable to tax has escaped assessment for any assessment year. However, this belief that income has escaped assessment has […]

Section 147/148 proceedings on mere investigation wing information was not valid

November 12, 2020 13089 Views 0 comment Print

Hitesh Ashok Vaswani Vs DCIT (ITAT Ahmedabad) In the present case the search information received from the investigation wing was used to form the reason to believe by the AO but without applying the mind. Thus the reasons were merely recorded on the borrowed satisfaction by the AO. The source for all the conclusions was […]

Section 80P deduction can be claimed while filing return in response to Section 148

November 10, 2020 32595 Views 3 comments Print

Daee Coop T&C Society Vs ACIT (ITAT Chennai) There is no dispute with regard to the fact that the assessee is a credit co-operative society registered under the TamilNadu Co­operative Societies Act, 1983. It is also not in dispute that the assessee is engaged in the business of providing credit facilities to its members. The […]

Additions in reopened Assessment not valid if no addition on subject matter of reopening

November 9, 2020 7581 Views 0 comment Print

The issue under consideration is whether the re-opening of assessment is valid even if there is no addition on subject-matter being basis for issuing notice under section 148, rather AO made addition on other counts?

No section 36(1)(iii) disallowance unless Direct Nexus between Borrowed Funds & Capital Withdrawals

November 4, 2020 2187 Views 0 comment Print

The issue under consideration is whether disallowance u/s 36(1)(iii) made by AO forming an opinion that interest bearing funds were withdrawn from the firm being capital withdrawn by the partners and interest free advances is justified in law?

Conditions Precedent for Reopening of Assessment beyond 4 Year- Section 147

October 22, 2020 4205 Views 0 comment Print

In view of the Proviso to s. 147, merely having a reason to believe that income had escaped assessment is not sufficient to reopen assessments but it must be specifically alleged by the AO in the recorded reasons that the escapement was on account of the failure of the assessee to make a full and true disclosure of material facts. In the absence of such allegation, the reopening is without jurisdiction;

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