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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 2844 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 90 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 114 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 99 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 93 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 453 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 5880 Views 0 comment Print


After expiry of 4 Years no notice u/s. 148 can be issued without approval of CCIT or CIT

November 12, 2015 1550 Views 0 comment Print

According to Section 151(1) proviso if the Assessing Authority who is below the rank of Assistant Commissioner or the Deputy Commissioner want to re­open the ‘case after the expiry of 4 years unless the Commissioner is satisfied that it is a fit case for issue of that notice. In the present case

Reopening of assessment beyond 4 years not permitted without finding assessee’s failure to produce material facts

November 11, 2015 3661 Views 0 comment Print

Delhi High Court held In the case of The Principal CIT vs. Samcor Glass Ltd. & M/s Samtel Color Ltd. that it is a settled position of law that reopening of assessment beyond 4 years is not sustainable unless there was a failure by the Assessee to disclose any material particulars

Revenue Must have Tangible Material to initiate income escaping Assessment

November 3, 2015 3339 Views 0 comment Print

In the case of Coperion Ideal Private Limited v. CIT, Delhi High Court while giving the decision in the favour of the assessee, held that there should be some tangible material available with the Revenue, whenever they want to conclude that Assessee have escaped Assessment.

Completion of reassessment without issue of reasons is invalid: HC

November 3, 2015 871 Views 0 comment Print

In the case of CIT v Trend Electronics, Bombay Court held that before issuance of reopening notice for assessment, the Revenue have to furnish the reasons for it. Otherwise, the notice will be considered as bad in Law.

Reopening of assessment not permissible where charges on Assessee are not specific: HC

October 31, 2015 1696 Views 0 comment Print

Delhi High Court held In the case of Oracle Systems Corporation vs. ADIT that it is clear that when a regular assessment is completed in terms of Section 143(3), a presumption can be raised that such an order has been passed upon a proper application of mind.

Reopening to rectify Mistake committed during Original Assessment not permissible

October 31, 2015 1279 Views 0 comment Print

Jindal Photo Films Ltd. vs. DCIT (Delhi High Court) 1998 234 ITR 170- Following the settled trend of judicial opinion and the law laid down by their Lordships of the Supreme Court time and again, different High Courts of the country have taken the view that if an expenditure

Re-opening of assessment not permissible on same set of materials considered in original assessment

October 31, 2015 886 Views 0 comment Print

Delhi High Court held In the case of Turner Broadcasting Systems Asia Pacific INC. vs. DDIT that the assessing officer has merely intended to revisit the concluded assessments and it is a clear case of change of opinion

Issue of notice u/s 143(2) before finalisation of reassessment order is mandatory

October 30, 2015 5902 Views 1 comment Print

Delhi High Court held In the case of Principal CIT vs. Shri Jai Shiv Shankar Traders Pvt. Ltd. that the failure by the AO to issue a notice to the Assessee under Section 143(2) subsequent to 16th December 2010

AO not empowered to initiate reassessment proceedings upon a mere change of opinion

October 30, 2015 5058 Views 0 comment Print

CIT vs Kelvinator of India Ltd. (Delhi High Court -Full Bench) [2002] 256 ITR 1/123- When a regular order of assessment is passed in terms of section 143 (3) of the Act, a presumption can be raised that such an order has been passed on application of mind.

AO is time bound to dispose of objections in response to notice u/s 148 by a speaking order: HC

October 29, 2015 2688 Views 0 comment Print

Delhi High Court held In the case of CIT vs. M/s Multiplex Trading & Industrial Co. Ltd. that the requirements regarding recording the reasons to believe; communicating the same to the Assessee; permitting the Assessee to file the objections

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