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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 60 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 258 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 735 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


Delay of 902 days condoned by considering complexity of Income Tax Laws: ITAT

July 4, 2023 777 Views 0 comment Print

In present facts of the case, the condonation of delay was allowed for 902 days by placing its reliance over the Judgments of Hon’ble Supreme Court and it was observed that Income-tax law is a complex subject and meeting its compliance requirements is dependent on services by experts of the subject matter. Accordingly the delay was condoned and the appeal was allowed on merits.

Transfer of Renewable Energy Certificate is capital and not taxable as business income

July 4, 2023 1518 Views 0 comment Print

ITAT Amritsar held that transfer of REC (Renewable Energy Certificate) is capital in nature and not liable to tax under business income as the income is offshoot from environmental concern not from offshoot of business concern.

Pre-clinical laboratory services by non-resident to Indian Customers not chargeable to tax in India

July 4, 2023 567 Views 0 comment Print

ITAT Bangalore held that pre-clinical laboratory services rendered by the assessee (non-resident) to its customers in India would not be chargeable to tax in India as the technical services rendered by the affiliates do not “make available” technical knowledge, experience, skill, know-how or process while preparing these reports for their, Indian customers/ clients.

Land transferred at the time of execution of Development Agreement cannot be taxed in year of Sale Agreement

July 3, 2023 5625 Views 0 comment Print

ITAT Mumbai held that land was transferred to the builder/ developer at the time of execution of Development Agreement i.e. 18/01/2008 and accordingly, the same cannot be taxed in the year of agreement of sale i.e. A.Y. 2010-2011.

Motor Vehicle Tax exempted on motor vehicles deployed to Central Deposit Yard Premises

July 3, 2023 585 Views 0 comment Print

Andhra Pradesh High Court held that motor vehicles deployed to Central Deposit Yard Premises are not subject to Motor Vehicle Tax and are entitled to get exemption as contemplated in Motor Vehicles Act.

Notice issued to ceased entity is fundamentally illegal and without jurisdiction

July 3, 2023 978 Views 0 comment Print

Gujarat High Court held that if the company has ceased to exist as a result of the approved scheme of amalgamation then in that case, the jurisdictional notice issued in its name would be fundamentally illegal and without jurisdiction.

Vehicles used in Central Deposit Yard is not leviable to motor vehicle tax

July 1, 2023 567 Views 0 comment Print

Held that the petitioner is plying the vehicles in the Central Deposit Yard premises itself proves that the premises does not fall under the definition of ‘public place’ as under Section 2 sub Section (34) of the Act. Hence, motor vehicle tax not leviable.

Addition in case of bogus purchases restricted to the extent of gross profit involved in business

June 30, 2023 2934 Views 0 comment Print

ITAT Mumbai held that 100% addition in case of bogus purchases unsustainable. Notably, addition to the extent of rate of gross profit in case of bogus purchase is duly sustained.

Order passed without proper service of notice u/s 147/148 is liable to be quashed

June 30, 2023 3720 Views 0 comment Print

ITAT Visakhapatnam held that the requirement of both the issuance and service of such notice upon the assessee for the purposes of Section 147 and 148 of the Act are mandatory jurisdictional requirements. Order passed is liable to be quashed on account of non-service of notice u/s 147/148.

AO not empowered to withdraw or modify or substitute order passed u/s 143(3) with another order

June 30, 2023 1803 Views 0 comment Print

ITAT Delhi held that statue doesn’t empower the Assessing Officer to withdraw or modify or substitute the assessment order passed under Section 143(3) of the Income Tax Act with another assessment order.

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