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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 5304 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1653 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 909 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2490 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...

March 9, 2025 45 Views 0 comment Print

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....

March 9, 2025 39 Views 0 comment Print

ITAT Surat Directs Re-examination of Tax on Gift from HUF

Income Tax : ITAT Surat remands case to CIT(A) for fresh adjudication on HUF gift taxability under Section 56(2)(vii) of the Income Tax Act, ci...

March 9, 2025 96 Views 0 comment Print

Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 219 Views 0 comment Print

Retrospective Amendment Doesn’t Justify Reassessment Beyond Four Years

Income Tax : Bombay High Court sets aside IT reassessment against Oxford University Press, ruling no failure to disclose material facts for reo...

March 8, 2025 144 Views 0 comment Print


Latest Notifications


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 246 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 9252 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 4086 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 5511 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 3021 Views 0 comment Print


Calcutta HC Stays Section 148 IT Notice Due to Limitation and Pending Appeal

June 14, 2024 2172 Views 0 comment Print

Calcutta High Court stays Section 148 notice for 2016-17 due to limitation issues and pending appeal. Jurisdictional conflicts lead to stay on further proceedings.

Delhi HC Invalidates Reassessment Notice, Upholds Section 149(1)(b) Time Limits

June 14, 2024 2238 Views 0 comment Print

Delhi High Court rules that reassessment actions post-2021 searches must meet the First Proviso to Section 149(1) of the Income Tax Act, quashing Dinesh Jindal case notice.

Audit objections alone do not fulfill criteria for reopening assessments: Delhi HC

June 13, 2024 1110 Views 0 comment Print

Delhi High Court invalidates reassessment proceedings against Samsung India for AY 2002-03, ruling lack of fresh tangible material after 4 years.

Subsidiary would only be deemed a PE if it satisfies specific tests outlined in DTAA

June 9, 2024 1050 Views 0 comment Print

Delhi High Court quashes reassessment notices by DCIT after TPO settles arm’s length remuneration issue. Detailed analysis of Progress Rail Locomotive Inc. vs DCIT case.

ITAT deletes Section 69A Addition in the hand of intermediary in fund transfer

June 9, 2024 1035 Views 0 comment Print

ITAT Ahmedabad deletes ₹4.45 crore addition under Section 69. Money from JDS Industries not deemed as Global Ship Trade P. Ltd’s income. Detailed case analysis.

Section 292BB cannot cure defect in notice to deceased assessee  

June 9, 2024 669 Views 0 comment Print

Read the detailed analysis of Late Lodaya Navalbai Vs ITO case by ITAT Bangalore. Learn why the reassessment proceedings were quashed and its implications.

No Income arises due to Transfers of amount from Current to Deposit Account

June 9, 2024 399 Views 0 comment Print

ITAT Chennai’s order regarding the transfer from current to deposit account as non-income, and deletion of addition. Full text of the order provided.

In absence of DTAA No tax on payments received by non-resident for IUC from Indian company

June 7, 2024 462 Views 0 comment Print

ITAT Bangalore ruled that payments received by a non-resident from an Indian company for interconnect utility charges cannot be taxed as royalty under section 9(1)(vi) of the Income Tax Act in the absence of a DTAA.

Kerala HC Sets Aside Appeal Dismissal Over Non-Compliance Technicality

June 7, 2024 339 Views 0 comment Print

Read the detailed analysis of Chandran Sarath Vs ACIT case by Kerala High Court where no income assessable to tax resulted in the dismissal of appeal. Full judgment text included.

ITAT directs AO to Tax only Peak Credit in respect of undisclosed Bank account

June 7, 2024 5298 Views 0 comment Print

ITAT Delhi directs verification of peak credits in the undisclosed ICICI Bank account in the case of Gulshan Grover vs ITO, addressing unexplained cash deposits.

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