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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 2841 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 63 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 105 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 96 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 90 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 447 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 5742 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


Section 263 Cannot Replace AO’s View on Reopening Issues

February 4, 2026 528 Views 0 comment Print

The case involved a Section 263 revision alleging failure to make additions after reopening. The Tribunal ruled that once the AO conducts enquiry and takes a conscious decision, revision is impermissible.

Generic Client Code Modification Allegations Insufficient for Reopening: Delhi HC

February 4, 2026 1116 Views 0 comment Print

The appeal was dismissed as the assessee had already offered the disputed income to tax at 30%. The ruling clarifies that reassessment cannot survive when there is no loss of revenue or escaped income.

ITAT Mumbai Deleted FBT Addition as Sales Promotion Expenses Gave No Employee Benefit

February 4, 2026 384 Views 0 comment Print

The Tribunal held that advertising and sales promotion expenses incurred on dealers and third parties cannot be treated as fringe benefits. The key takeaway is that FBT applies only where expenditure amounts to consideration for employment.

Reopening Below ₹50 Lakh Without PCCIT Approval Is Invalid

February 4, 2026 303 Views 0 comment Print

The issue concerned reopening based on notices never validly served on the assessee. The Tribunal held that defective service of notices strikes at the root of jurisdiction and invalidates the reassessment.

Unaccounted Liquor Sales—Profit to Be Estimated, Not Gross Receipts Taxed: ITAT Chandigarh

February 3, 2026 648 Views 0 comment Print

The Tribunal held that once business receipts are taxed on an estimated basis, separate additions for payments and assets from the same receipts are impermissible. Only a net-profit estimation was sustained, deleting multiple cascading additions.

Notice issued u/s. 148 beyond 3 years is time barred as escapement is less than 50 Lakhs

February 3, 2026 1359 Views 0 comment Print

ITAT Hyderabad held that limitation for issuing notice under section 148 of the Income Tax Act would be only 3 years from the end of the assessment year since material suggesting escapement is less than Rs. 50 Lakhs. Hence, notice issued u/s. 148 is beyond period of limitation of three years hence quashed.

Reopening Challenge Rejected; Revenue Difference Issue Sent Back

February 3, 2026 255 Views 0 comment Print

The tribunal refused to admit a fresh legal challenge to reassessment raised for the first time. However, it remanded the revenue-difference addition for fresh adjudication due to natural justice concerns.

Unsigned Approval u/s 151 Vitiates Reassessment: ITAT Rajkot Quashes Reopenings in Classic Network Pvt. Ltd. Group Case

February 3, 2026 1218 Views 0 comment Print

Reopenings based on assumptions, conjecture, or generalized allegations were struck down. The ruling reiterates that reasons must show tangible material, application of mind, and a live nexus with escaped income.

Section 68 Addition Deleted Due to Proven Identity and Source of Loans

February 3, 2026 351 Views 0 comment Print

The Tribunal upheld deletion of unsecured loan additions after finding that the lenders identity, bank trail, and reserves were established. Low declared income alone was held insufficient to treat the credits as unexplained.

Renewal of Old Fixed Deposits Is Not Unexplained Investment: ITAT Delhi Upholds Deletion of Section 69 Addition

February 3, 2026 552 Views 0 comment Print

Despite non-compliance during assessment, the Tribunal upheld deletion of additions where facts showed only renewal of deposits. Ex-parte proceedings do not justify treating old FDs as unexplained investments.

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