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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 69 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 96 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 450 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


Bogus Purchases: ITAT Mumbai Restricts Addition to 5% Where Sales Are Undisputed

January 23, 2026 621 Views 0 comment Print

The issue was whether a flat 12.5% disallowance on alleged bogus purchases was justified. The Tribunal ruled that when sales are accepted and books are not rejected, only a lower, reasonable estimation can apply, capping it at 5%.

Penalty Deleted Where Income Already Disclosed & Additions Lead to Double Taxation

January 23, 2026 513 Views 0 comment Print

The Tribunal held that penalty cannot survive where sales were already offered to tax and later added again under section 68. The key takeaway is that double taxation cannot result in penalty when no tax was sought to be evaded.

Change of Opinion: ITAT Pune Quashes Reassessment; Section 68 & 40(a)(ia) Additions Fail

January 23, 2026 483 Views 0 comment Print

The issue was whether reassessment could be reopened on matters already examined in scrutiny. The Tribunal held that without fresh tangible material, reopening amounts to change of opinion and is invalid.

ITAT Mumbai Quashes Reopening Beyond 4 Years; Sub-Contract Disallowance Deleted

January 23, 2026 372 Views 0 comment Print

The Tribunal deleted the disallowance after finding that work orders, invoices, and bank payments established genuineness of expenses. The ruling clarifies that suspicion alone cannot override documentary evidence.

Notional JDA Income Not Taxable Without Real Accrual: ITAT Pune

January 23, 2026 363 Views 0 comment Print

The issue was whether notional income booked on a joint development agreement can be taxed before project commencement. The Tribunal held that only real income can be taxed and deleted the disallowance.

Reassessment Quashed for Failure to Dispose Objections Before Order: ITAT Mumbai

January 23, 2026 594 Views 0 comment Print

The issue was whether reassessment could survive when objections to reopening were ignored. The Tribunal ruled that non-disposal of objections violates mandatory procedure and renders the reassessment void ab initio.

Section 69 Cannot Be Invoked for Recorded Share Investments Merely for Premium Mismatch

January 23, 2026 2514 Views 0 comment Print

The issue was whether a recorded share investment can be treated as unexplained under Section 69. The Tribunal held that once an investment is recorded in the books and its source is not doubted, Section 69 cannot be invoked.

Reassessment Addition Based Solely on Retracted Third-Party Statements Quashed: ITAT Mumbai

January 23, 2026 588 Views 0 comment Print

The reassessment relied entirely on allegations arising from a search on another entity. The Tribunal ruled that additions cannot survive without independent evidence directly linking the assessee.

Reassessment Quashed for Failure to Record Reasons Under Section 148: ITAT Mumbai

January 23, 2026 336 Views 0 comment Print

The issue was whether reassessment is valid when reasons for reopening are not placed on record. The Tribunal held that non-recording of reasons under Section 148(2) vitiates jurisdiction, rendering the reassessment void.

Section 163 Inapplicable Without Direct or Indirect Income Flow to NRI: ITAT Hyderabad

January 22, 2026 813 Views 0 comment Print

This ruling clarifies that an assessee can be treated as an agent of a non-resident only if income is received directly or indirectly for the NRI. In the absence of such receipt or business connection, representative assessment fails.

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