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Section 147

Latest Articles


Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 6573 Views 0 comment Print

Recent Judgements of Supreme Court on Income Tax Issues

Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....

January 22, 2024 8358 Views 1 comment Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...

December 10, 2023 19590 Views 7 comments Print


Latest News


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 6936 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 12900 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 41382 Views 2 comments Print

Notices for assessment/reassessment of income of old cases

Income Tax : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...

August 3, 2018 1893 Views 0 comment Print

No Reopening of Assessment to be made on Audit Objections: Committee Recommends

Income Tax : One of the key sources of dispute is the existing arrangement for follow up on audit objections by Internal Audit Party and the Re...

January 20, 2016 6657 Views 0 comment Print


Latest Judiciary


Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 60 Views 0 comment Print

Reassessment cannot be based solely on reevaluating existing facts without new substantive material

Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...

July 17, 2024 60 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 126 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 258 Views 0 comment Print

Non-Filing of GST Return by Supplier – Assessment Reopening Validity- ITAT Mumbai Order

Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...

July 17, 2024 735 Views 0 comment Print


Latest Notifications


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 8571 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 3063 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 5337 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 2934 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 14292 Views 1 comment Print


No Penalty under 271(1)(c) if income is furnished to Tax Authorities at initial assessment stage

August 20, 2023 5409 Views 0 comment Print

Ashvin Narayan Bajoria (HUF) Vs ITO (ITAT Surat) Recently the SMC Bench of Surat Income Tax Appellate Tribunal passed a judgement in the aforementioned case deleting the penalty levied by the Ld. Assessing Officer under section 271(1)(c) of the Act for concealment of income. The central point of discussion was whether or not penalty imposed […]

Reassessment Under Income Tax Act, 1961 (Pre & Post ‘Ashish Agarwal’)

August 20, 2023 3720 Views 0 comment Print

We will delve into key highlights of Reassessment: Pre and Post Ashish Agarwal Judgement delivered by Supreme Court along with subsequent CBDT Direction 1/2022 (dated 11-05-2022)

Notice issued u/s 153C without valid satisfaction notice is bad-in-law

August 19, 2023 4284 Views 0 comment Print

ITAT Jaipur held that in absence of a valid satisfaction note the notice issued under Section 153C of the Income Tax Act 1961 is bad in law. Resultantly the assessment order passed u/s 143(3) r.w.s. 153C of the Act is void ab initio and liable to be quashed.

Reasons for reopening recorded by authority not having territorial jurisdiction is bad-in-law

August 18, 2023 660 Views 0 comment Print

ITAT Kolkata held that reasons for reopening of the assessment recorded by an Authority who was not having territorial jurisdiction over the assessee is unsustainable in law and accordingly the entire reassessment proceeding is liable to be quashed.

Re-assessment of income u/s 147 merely based on change of opinion invalid

August 18, 2023 1413 Views 0 comment Print

ITAT Surat held that section 147 doesn’t allow the re-assessment of an income merely because of the fact that AO has change of opinion with regard to the interpretation of law differently on the facts that were well within his knowledge even at the time of assessment.

Incriminating Material found during search of third party: Section 153C vs. 147

August 18, 2023 1830 Views 0 comment Print

ITAT Delhi held that addition based on incriminating material found during the search carried out of ‘some other person’ i.e. third person/ party and assessing the same by invoking provision of section 147 instead of section 153C is unsustainable.

HC Dismisses Writ for Petitioner’s Delay in Approaching the Writ Court

August 16, 2023 1083 Views 1 comment Print

Analysis of Jay Shree Tea And Industries Limited Vs ACIT in Calcutta High Court. Judgement on delay in approaching writ court, AY 2013-14. Full text.

HC Dismisses Writ Challenging Section 148A(d) Order, Citing Alternative Remedy

August 15, 2023 3813 Views 0 comment Print

Calcutta High Court ruling on invoking writ jurisdiction under Section 148A(d) of the Income Tax Act in Tezas Trading Co. case. Read the judgment here.

Writ Petition Inadmissible if Assessment Order is Appealable: Calcutta HC

August 15, 2023 684 Views 0 comment Print

Calcutta HC rules a writ petition can’t be entertained if the order is appealable. Insight into Euphoria Infotech India PVT LTD. vs ITO case.

Wrong PAN Quotation in Reassessment: Calcutta HC Review

August 15, 2023 633 Views 0 comment Print

Calcutta HC examines the case of Tribeni Barters Pvt. Ltd., where the wrong PAN was quoted in a reassessment. Court orders presentation of relevant records.

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