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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 2844 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 81 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 99 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 453 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


CIT(A) Cannot Bypass Jurisdictional Grounds by Simple Remand: ITAT Amritsar

January 28, 2026 315 Views 0 comment Print

The issue was whether the appellate authority could bypass jurisdictional objections by remanding the case. The tribunal held that legal grounds striking at jurisdiction must be adjudicated first.

Penalty on Deceased Assessee Void, Section 271AAC Order Quashed: ITAT Mumbai

January 27, 2026 1146 Views 0 comment Print

The Tribunal held that a penalty order issued after the death of the assessee is void ab initio. Since notices were not served on legal heirs, the penalty under section 271AAC was set aside.

Suspicion Cannot Replace Evidence, Ad-Hoc Commission Addition Partly Set Aside

January 27, 2026 348 Views 0 comment Print

The Tribunal held that additions based solely on third-party GST information and suspicion cannot be sustained without independent investigation, restricting estimation to 1% of sales.

Redevelopment Compensation is Capital Receipt, Not Taxable as Income: ITAT Mumbai

January 27, 2026 1506 Views 0 comment Print

The Tribunal ruled that compensation and hardship allowance received during redevelopment are capital receipts and cannot be taxed as income from other sources.

Only Profit in Brokerage Receipts Taxable, Not Gross Amount: ITAT Hyderabad

January 27, 2026 588 Views 0 comment Print

The issue was whether entire brokerage receipts credited to a bank account could be taxed as income. The Tribunal held that only the profit element is taxable and estimated income at 25% of gross commission.

Reopening Invalid Where Capital Gains Already Disclosed and Taxes Paid

January 27, 2026 648 Views 0 comment Print

The Tribunal quashed reassessment proceedings after finding that the Assessing Officer already possessed complete information before issuing notice under section 148.

Bank Account Used as Conduit: Entire Credits Not Taxable; Only Commission Income Assessable

January 27, 2026 231 Views 0 comment Print

The ITAT held that gross bank credits cannot be treated as unexplained income where evidence shows the assessee merely facilitated transactions for a third party. Only a reasonable commission was directed to be taxed.

Direct ITAT Appeal Rejected Due to Failure to Approach DRP

January 27, 2026 351 Views 0 comment Print

The Tribunal held that when an eligible assessee fails to file objections before the DRP within time, a direct appeal to the Tribunal is barred. Non-compliance with section 144C renders the appeal non-maintainable.

Reassessment Quashed for Sanction by Incompetent Authority

January 27, 2026 327 Views 0 comment Print

The Tribunal held that reassessment initiated with approval from an incorrect authority violates section 151. Such jurisdictional defect renders the section 148 notice void.

Only Commission Income Taxable in Money Transfer Activity; Entire Cash Deposits Cannot Be Treated as Income

January 27, 2026 855 Views 0 comment Print

The Tribunal held that cash routed through a bank account for money transfer activity cannot be taxed in full when only commission is earned. Once commission income is offered to tax, no further addition is justified.

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