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Section 147

Latest Articles


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 36 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 105 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


AO cannot do reassessment after assessment by Settlement Commission

May 6, 2019 5484 Views 0 comment Print

Since there was an order of the Settlement Commission under section 245D(4) in relation to the assessment year in respect of which assessment was sought to be reopened, AO had no jurisdiction to reopen the assessment as once an order had been passed under section 245D by Settlement Commission, assessment for year stood concluded. 

S.147 Basic condition of ‘reason to believe’ applies even to s.143(1) intimations

May 5, 2019 3057 Views 0 comment Print

Bombay High Court case – Ankita Choksey challenges re-opening notice under Income Tax Act, 1961. Assessing Officer’s jurisdictional challenge discussed.

Reassessment for Change of opinion not objected during Assessment- HC dismisses writ petition

May 5, 2019 1101 Views 0 comment Print

Firstly, we may observe that the learned Single Judge was absolutely right in holding that the Assessee, having not raised an objection before the Assessing Authority to the re-opening of the assessment under Section 147/148 of the Act, should be deemed to have acquiesced to the same. Nothing prevented the Assessee from raising the objection, which could have been dealt with by the Assessing Authority in accordance with law.

Revisionary power U/s. 263 cannot be exercised on ground not covered in Re-Opening

May 3, 2019 4092 Views 0 comment Print

Gulab Badgujar (HUF) Vs CIT (Central) (ITAT Pune) The question which arises is the exercise of revisionary jurisdiction by the Commissioner of Income Tax under section 263 of the Act against the order passed under section 143(3) r.w.s. 147 of the Act, wherein the assessment proceedings were re-opened on specific reasons recorded for re-opening. We […]

Reassessment by sending section 148 notice to old address of assessee is invalid

May 3, 2019 4218 Views 0 comment Print

Veena Devi Karnani Vs ITO (Delhi High Court) Rule 127(2) clearly states that the addresses to which a notice or summons or requisition or order or any other communication may be delivered or transmitted shall be either available in the PAN database of the assessee or the address available in the income tax return to […]

Best judgment assessment- Salary & interest to partners can be disallowed

May 2, 2019 3663 Views 0 comment Print

ITAT held that As there was part non-compliance by assessee with first notice under section 142(1) and complete non-compliance with subsequent notice under section 142(1), the AO was right in framing assessment order under section 144 and in denying allowance of interest and salary paid to partners by taking support of provisions of section 184(5).

Reason to believe that Income has escaped Assessment applies even in case of non-filing of return

April 23, 2019 2409 Views 0 comment Print

Mohanlal Champalal Jain Vs ITO (Bombay High Court) Assessing Officer has proceeded on wrong premise that even when called upon to state why the petitioner had not filed return of income, he had not responded to the said query. The petitioner did communicate to the Department that he had no taxable income and therefore, there […]

Notice for reopening of assessment against a dead person is invalid

April 21, 2019 2454 Views 0 comment Print

Impugned notice of reopening of assessment was issued on a dead person. There are several judgments of different High Courts holding that the notice or reopening of assessment is invalid in law. Suffice it to say, as per the settled law, notice for reopening of assessment against a dead person is invalid.

Reassessment when Assessee made AO left with little time to complete assessment

April 18, 2019 3033 Views 0 comment Print

Cenveo Publisher Services India Ltd Vs. UOI (Bombay High Court) In this case the petitioner raised objections promptly after withdrawing the petition from this Court, would not in any manner dilute the fact that it was on the ground of the petitioner’s conduct that the Assessing Officer was left with little time to dispose of […]

Reassessment on change of opinion on provision for bad & doubtful debts is invalid

April 17, 2019 897 Views 0 comment Print

CIT Vs. M/s. Indian Potash Ltd. (Madras High Court) The Tribunal has recorded a factual finding that the Assessee has disclosed the figure of provision for bad debts and doubtful debts and interest income also in the Profit and Loss Account submitted along with the return of income. Therefore, the Tribunal held that there is […]

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