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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 96 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 66 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 84 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 Delhi Quashes Search Assessments for Mechanical Approval u/s 153D; Entire Proceedings Held Non-Est

January 22, 2026 618 Views 0 comment Print

The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.

Reassessment Quashed for Invalid Sanction u/s 151: Approval by PCIT Instead of PCCIT Held Void

January 22, 2026 981 Views 0 comment Print

The reassessment was challenged for lacking approval from the correct authority under Section 151 after three years. The Tribunal held that sanction by an incorrect authority vitiates jurisdiction, rendering the reassessment void.

Section 143(3) Order Invalid as Assessment Had Abated on Search Date

January 22, 2026 990 Views 0 comment Print

The Tribunal ruled that completion of assessment after search, despite statutory abatement, is impermissible. Jurisdiction shifts exclusively to Section 153A proceedings.

Reassessment Beyond 3 Years Upheld as Escapement Exceeded ₹50 Lakh — Cash Deposits u/s 69A

January 22, 2026 354 Views 0 comment Print

The issue was whether reassessment after three years was barred by limitation. The Tribunal held it valid since the escaped income exceeded ₹50 lakh, attracting the extended reopening window.

ITAT Rajkot Quashes Copy-Paste Appellate Order Citing Wrong AY/Facts

January 22, 2026 5514 Views 1 comment Print

The issue was an appellate order passed with facts, year, and income of another assessee. The Tribunal held the order void and directed a fresh decision in the correct case.

Penny Stock LTCG Held Genuine Despite Investigation Reports: ITAT Mumbai

January 22, 2026 6234 Views 0 comment Print

The tribunal held that suspicion, abnormal price rise, or third-party reports are insufficient to deny LTCG exemption. Revenue must establish direct involvement of the taxpayer in price rigging.

Section 263 Invoked for TDS Default on Freight: ITAT Patna Upholds Revisionary Order

January 22, 2026 219 Views 0 comment Print

ITAT ruled that the AO’s omission to apply TDS provisions on freight charges warrants revision. Proper application of statutory disallowances is mandatory in reassessment proceedings.

Bogus Share Deals: Section 68 Addition Limited to 2% Commission

January 22, 2026 504 Views 0 comment Print

ITAT ruled that principal amounts in accommodation share entries do not constitute income of a conduit entity. Taxability is restricted to the commission earned for facilitating such transactions.

Section 271(1)(c) Penalty Invalid for Non-Specification of Charge: ITAT Agra

January 22, 2026 552 Views 0 comment Print

The issue was whether retaining both limbs of Section 271(1)(c) in the notice renders the penalty void. The Tribunal ruled that failure to strike off the inapplicable limb vitiates the proceedings. Penalties must be founded on precise allegations.

ITAT Mumbai Allowed Section 54F Claim in Appeal although Not Made in Return

January 22, 2026 2211 Views 0 comment Print

It was ruled that the bar on fresh claims applies only to assessing officers, not appellate bodies. A valid Section 54F claim must be examined on merits during appeal.

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