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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 4971 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1653 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 909 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2490 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...

March 9, 2025 27 Views 0 comment Print

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....

March 9, 2025 27 Views 0 comment Print

ITAT Surat Directs Re-examination of Tax on Gift from HUF

Income Tax : ITAT Surat remands case to CIT(A) for fresh adjudication on HUF gift taxability under Section 56(2)(vii) of the Income Tax Act, ci...

March 9, 2025 63 Views 0 comment Print

Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 210 Views 0 comment Print

Retrospective Amendment Doesn’t Justify Reassessment Beyond Four Years

Income Tax : Bombay High Court sets aside IT reassessment against Oxford University Press, ruling no failure to disclose material facts for reo...

March 8, 2025 138 Views 0 comment Print


Latest Notifications


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 246 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 9252 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 4083 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 5511 Views 0 comment Print

Time barring date for reopening cases arising out of SC direction

Corporate Law : Income Tax Gazetted Officers’ Association (W.B.) Unit Date: 02.02.2023. To The Principal Chief Commissioner of Income Tax, W...

February 2, 2023 3021 Views 0 comment Print


ITAT held revision u/s 263 could not address issues beyond limited scrutiny under CASS

August 22, 2024 609 Views 0 comment Print

Assessee-partnership firm had filed its income tax return declaring income. The case was selected for limited scrutiny, focusing on the issues such as investment in immovable property and share capital/other capital.

Notice u/s. 148 cannot be issued after expiry of four/six years: Delhi HC

August 22, 2024 2115 Views 0 comment Print

Delhi High Court held that that no notice under section 148 of the Income Tax Act shall be issued if four years “but not more than six years” have elapsed from the end of the relevant assessment year.

Filing of Form 10B is a procedural requirement & should not negate substantive claim of exemption

August 19, 2024 894 Views 0 comment Print

Delhi ITAT rules that the requirement of filing Form 10B is procedural, allowing Section 11 exemption for an educational trust despite delayed filing.

Ex-Parte Order Without Adjudication on Merits is Unsustainable: ITAT Ahmedabad

August 18, 2024 441 Views 0 comment Print

ITAT Ahmedabad held that passing of ex-parte order by CIT(A) without adjudicating issues on merits, such order is not sustainable in the eyes of law keeping in view provisions of Section 250(6) of the Income Tax Act.

Section 153A Addition Valid Only if Based on Material Seized during search: ITAT Kolkata

August 18, 2024 357 Views 0 comment Print

ITAT Kolkata held that additions u/s. 153A of the Income Tax Act could only be made on the basis of seized material found during the course of search. Thus, making additions in regular assessment without any incriminating material relating to said addition not justified.

Passing of Section 148A(d) order based on fresh ground untenable: Delhi HC

August 17, 2024 2157 Views 0 comment Print

Delhi High Court held that passing of order by the revenue under section 148A(d) of the Income Tax Act on the basis of fresh ground which was never taken up with the assessee in the notice is untenable in law.

Section 68 Addition Justified Due to Unproven Genuineness & Creditworthiness: ITAT Ahmedabad

August 17, 2024 681 Views 0 comment Print

ITAT Ahmedabad held that genuineness of transaction, creditworthiness and identity of creditors not proved, hence addition u/s. 68 of the Income Tax Act towards unexplained credit duly sustained.

Advance tax payment provisions doesn’t apply to reassessment proceedings: ITAT Indore

August 17, 2024 792 Views 0 comment Print

ITAT Indore held that rejection of appeal by CIT(A) on the footing of non-payment of advance tax as required by section 249(4)(b) untenable as payment of advance tax is not applicable in case of reassessment proceedings.

Section 148 to notice NRI Without Mandatory Faceless Procedure Unsustainable: Telangana HC

August 17, 2024 1605 Views 0 comment Print

Telangana High Court held that notice issued u/s. 148 of the Income Tax Act must comply with the requirement of the Scheme whether or not the Taxpayer is NRI/Indian Citizen. Thus, issuance of notice to NRI u/s. 148 without following mandatory faceless procedure is set aside.

Bogus purchase addition cannot be based on superficial inquiry: Bombay HC

August 17, 2024 2703 Views 0 comment Print

Bombay High Court held that half-hearted approach on the part of AO to make additions on the issue of bogus purchase would not be conducive. Bogus purchase addition also cannot be on the basis of superficial inquiry.

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