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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 63 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 261 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 738 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


Allowability of Interior Decoration Work in Rented Office as Revenue Expenditure

August 7, 2023 1314 Views 0 comment Print

ITAT Kolkata held that expenditure incurred towards interior decoration work of a rented office premises is allowable as revenue expenditure. Accordingly, disallowance of such expenditure unjustified.

Notice u/s 148 can be Issued on Assessee’s Failure to truly disclose Material Facts: ITAT

August 6, 2023 1704 Views 0 comment Print

In present facts of the case, the Hon’ble Tribunal set aside Notice under Section 148 by making observation that the ld. Assessing Officer failed to pinpoint the failure at the end of the assessee to disclose all material facts fully and truly, which led the escapement of income from taxation.

Assessment Invalidated by ITAT: Reopening Beyond Four Years

August 6, 2023 1290 Views 0 comment Print

Discover the key points from the Samridhi Stocks Pvt Ltd vs ITO case at ITAT Kolkata, where a late assessment reopening was invalidated.

ITAT Ruling on Reopening Based on Retracted Statement

August 6, 2023 762 Views 0 comment Print

A comprehensive review of ITAT Delhi’s ruling on DCIT Vs Saarthak Vanijya India Ltd case, about the viability of reassessment based on retracted statements.

Delhi HC Quashes Section 147 Order Passed Without Issuing SCN

August 6, 2023 2622 Views 0 comment Print

Delhi High Court invalidates the income revision u/s 147 of Income Tax Act by ITO against SB Distributors due to the absence of Show Cause Notice.

Capital Gain Taxable in Year of Land Possession Granted to Developer

August 5, 2023 1917 Views 0 comment Print

ITAT Visakhapatnam held that capital gain taxable in the year in which possession of land is granted to the developer vide the original development agreement and not in the year in which supplementary agreement is entered.

Rendering cloud computing services not liable to tax in India as royalty or FTS/FIS

August 5, 2023 4290 Views 0 comment Print

ITAT Delhi held that rendering cloud computing services/ Amazon Web Services (AWS Services) cannot be held to be liable to tax in India either as royalty or as Fees for Technical Services (FTS)/ Fees for Included Services (FIS).

Reopening of assessment quashed as PCIT granted approval without adequate inquiry

August 5, 2023 1533 Views 0 comment Print

Delhi High Court held that reopening of assessment liable to be quashed as PCIT simply rubber-stamped the attempt of AO to reopen the assessment without inquiring about various basic issues involved in the matter like applicability of section 50C, cost of acquisition and claim of deduction u/s 54EC.

Advance forfeited without transfer of capital assets is taxable as ‘Income from Other Sources’

August 5, 2023 1473 Views 0 comment Print

ITAT Mumbai held that as per Section 56(2)(ix) of the Act money received as advance would be treated as income liable to tax in the hands of recipients under the head ‘Income from Other Sources’ provided such advance is forfeited and the negotiations do not resulted in transfer of the capital assets.

Reassessment after 4 years without failure to disclose full & true material facts unsustainable

August 5, 2023 1062 Views 0 comment Print

Bombay High Court held that initiation of reassessment proceedings u/s 147 after the expiry of 4 years from the end of the relevant assessment years without failure on the part of the assessee to disclose fully and truly all the material facts unsustainable and liable to be quashed.

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