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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 57 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 99 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 78 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 87 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


ITAT Chandigarh Quashed Reassessment Beyond Four Years for No Disclosure Failure

January 29, 2026 534 Views 0 comment Print

The Tribunal held that reopening after four years is invalid without alleging failure to disclose material facts. The reassessment was barred by the proviso to section 147.

Rural Agricultural Land Outside Section 56(2)(vii)(b): ITAT Deletes ₹59.33 Lakh Addition

January 29, 2026 837 Views 0 comment Print

The Tribunal held that rural agricultural land excluded from capital asset under Section 2(14) cannot be taxed under Section 56(2)(vii)(b). Addition based on stamp duty valuation was therefore deleted in full.

Interest from Deposits with Co-operative Banks Qualifies for Section 80P(2)(d): ITAT Allows Deduction in Full

January 29, 2026 378 Views 0 comment Print

The disallowance of interest income was set aside as co-operative banks fall within the definition of co-operative societies. The ruling confirms full deductibility of such interest under Section 80P(2)(d).

Interest from Co-operative Banks Eligible for Section 80P(2)(d): ITAT Remands for Limited Verification

January 29, 2026 348 Views 0 comment Print

The Tribunal held that interest earned by a co-operative society from investments with co-operative banks falls within Section 80P(2)(d). Such income is deductible, subject to verification of the source and bifurcation.

Cash Deposits of Mobile Recharge Distributor Not Unexplained: ITAT Upholds Deletion of ₹1.95 Crore Addition

January 29, 2026 444 Views 0 comment Print

Cash deposits followed by regular transfers to the telecom operator established a clear business cycle. The ruling confirms that explained business receipts cannot be treated as unexplained cash.

Reopening under Section 147 Invalid Where Search Material Triggers Section 153C

January 29, 2026 996 Views 0 comment Print

The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.

Section 69A Addition Quashed Where Presumptive Income Was Declared

January 29, 2026 1191 Views 0 comment Print

The Tribunal held that receipts already offered under the presumptive scheme cannot be taxed again as unexplained money. Once income is declared under section 44AD and supported by surrounding facts, section 69A has no application.

Reassessment Quashed as No Addition Made on Original Reopening Issue

January 28, 2026 1002 Views 0 comment Print

The Tribunal held that reassessment under section 147 fails when the alleged income escapement cited for reopening is accepted and no related addition is made. Without sustaining the original reason for reopening, jurisdiction itself collapses.

Mere Claims of Cheque Discounting Insufficient to Explain Bank Credits: ITAT Surat

January 28, 2026 1275 Views 0 comment Print

The Tribunal upheld the remand of an ex parte assessment where substantial bank deposits were not supported by any documentary evidence. It held that unsupported explanations cannot replace proof, and fresh verification by the Assessing Officer was necessary.

Bogus Purchases Can’t Be Added in Full When Sales Are Accepted: ITAT Restricts Addition to 3% GP

January 28, 2026 543 Views 0 comment Print

The case examined the tax treatment of purchases from alleged accommodation entry providers. The Tribunal held that at best, only the profit element embedded in such purchases can be brought to tax.

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