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Section 147

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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 390 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 573 Views 0 comment Print

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 729 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 1032 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 3180 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 2277 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 4386 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 7494 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 13344 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 42813 Views 2 comments Print


Latest Judiciary


ITAT Mumbai Quashes Reassessment as Section 148 Notice Was Issued Beyond Surviving Limitation Period

Income Tax : ITAT Mumbai held that the reassessment notice issued on 24.07.2022 was time-barred under the Supreme Court ruling in Rajeev Bansal...

May 20, 2026 84 Views 0 comment Print

ITAT Delhi Quashes Reassessment as Reopening Was Based Only on Audit Objection

Income Tax : The Delhi ITAT held that reassessment proceedings initiated solely on the basis of a revenue audit objection without fresh tangibl...

May 20, 2026 78 Views 0 comment Print

Reassessment Quashed as AO Used Section 147 Instead of Mandatory Section 153C

Income Tax : ITAT Ahmedabad held that reassessment based solely on search material seized from a third party must be initiated under Section 15...

May 20, 2026 141 Views 0 comment Print

Section 263 Proceedings Quashed as AO’s Order Was Not Erroneous in Jewellery Case

Income Tax : The Tribunal held that the reassessment order could not be revised under Section 263 since the conditions for treating jewellery e...

May 20, 2026 93 Views 0 comment Print

Bangalore ITAT Grants Relief in Section 50C Addition – DVO Valuation in Co-Owner’s Case Accepted Over Stamp Duty Value

Income Tax : The ITAT ruled that the Assessing Officer wrongly adopted the stamp duty valuation despite contrary valuation material on record. ...

May 20, 2026 111 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 5817 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 846 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 10302 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 5892 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 5907 Views 0 comment Print


Borrowed Satisfaction and Mechanical U/s 151 Approval Invalidate 147 Reopening – ITAT Kolkata

February 21, 2026 435 Views 0 comment Print

TAT Kolkata ruled that reopening based on unverified foreign information amounted to borrowed satisfaction. Since the sanctioning authority granted approval mechanically, the reassessment was declared void.

Delhi HC Dismisses Reopening Based Solely on Audit Objection

February 20, 2026 660 Views 0 comment Print

elying on Supreme Court precedent, the Court upheld ITAT’s finding that reopening based on reappraisal of existing records is invalid. The Revenue’s appeal was dismissed.

ITAT Bangalore: Cost of Construction Cannot Be Fully Disallowed; Matter Remanded to AO for Fresh Verification & Valuation

February 20, 2026 606 Views 0 comment Print

The ITAT Bangalore held that the entire cost of construction claimed by the assessee while computing capital gains on sale of property could not be outrightly disallowed merely due to lack of complete supporting documents.

ITAT Bangalore Quashes Reopening Based on Wrong Bogus LTCG Assumption; Deletes Double Addition U/s 68

February 20, 2026 378 Views 0 comment Print

The ITAT Bangalore held that reopening of assessment was invalid as it was based on an incorrect assumption that the assessee had claimed bogus long-term capital gains (LTCG) from penny stock transactions.

ITAT Quashes ₹11.23 Cr Reassessment as Section 148 Notice Held Time-Barred

February 20, 2026 699 Views 0 comment Print

The Tribunal held that the reassessment notice issued after the extended limitation period was invalid under Section 149. As a result, the entire reassessment based on alleged accommodation entries was quashed as void ab initio.

ITAT Restores Appeal After Wrongful Dismissal for Non-Payment of Advance Tax

February 20, 2026 438 Views 0 comment Print

The Tribunal held that Section 249(4)(b) does not apply in reassessment where no advance tax liability existed, setting aside dismissal of appeal and restoring it for decision on merits.

Reassessment Quashed as Year of Search Cannot Be Reopened Under Section 148

February 19, 2026 684 Views 0 comment Print

The Tribunal held that reassessment under Sections 147/148 is invalid when the assessment year is the year of search. Such cases must proceed under normal assessment provisions.

Bombay HC Quashes Reassessment as Section 148 Notice Issued by Wrong Authority

February 19, 2026 1119 Views 0 comment Print

The Court held that issuance of notice under Section 148 by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer is a jurisdictional defect. All consequential reassessment proceedings were set aside.

Mere Third-Party Excel Sheet Insufficient for Section 69 Addition: ITAT Chandigarh

February 19, 2026 5376 Views 0 comment Print

The alleged unexplained investment was based only on third-party statements and seized digital data. In absence of receipts, confirmations, or admission by the assessee, the addition of ₹50 lakh was deleted.

ITAT Guwahati Quashes Reassessment Notice, Treats Loose Sheets as Dumb Documents, Deletes Protective Sec 69C Addition

February 19, 2026 711 Views 0 comment Print

ITAT dismissed the Revenues appeal because it did not contest the CIT(A)s ruling that the reassessment notice was legally invalid. Without challenging the jurisdictional defect, the appeal became infructuous.

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