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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


Assessment Held Void for Skipping Statutory Notice Under Section 143(2): ITAT Agra

January 22, 2026 582 Views 0 comment Print

This case involved reassessment completed without serving the mandatory scrutiny notice. The Tribunal ruled that such omission is not a curable defect and invalidates the proceedings. The decision reinforces strict adherence to statutory safeguards.

ITAT Ahmedabad: CIT(A) Order Vitiated for Mixing Two Years’ Facts; Remanded

January 22, 2026 573 Views 0 comment Print

It was ruled that deciding appeals based on facts of another year is a serious legal error. The matter was sent back for reconsideration on correct facts.

ITAT Agra Upholds Separate NP Rates: 0.22% (Animal Trading) & 8.7% (Scrap)

January 22, 2026 315 Views 0 comment Print

The dispute centered on profit estimation after reopening for suppressed turnover. The Tribunal affirmed lower NP for animal sales, recognising industry norms and assessee history. The ruling underscores tailoring estimates to trade economics.

Reassessment Order Struck Down for Jurisdictional Defect

January 22, 2026 837 Views 0 comment Print

The Tribunal held that NFAC had no authority to pass reassessment orders before the faceless reassessment notification became operative. As a result, the entire assessment was quashed. The ruling highlights that participation by the assessee cannot cure jurisdictional defects.

Interest for Late Original Return Valid Despite Timely Search Filing: ITAT Ahmedabad

January 22, 2026 351 Views 0 comment Print

It was ruled that interest for late filing of the original return can be computed based on tax determined in search-related assessment. Timely filing after notice does not negate earlier delay.

Entire Bogus Purchases Cannot Be Added When Sales Accepted: ITAT Dehradun Restricts Addition to 4%

January 21, 2026 690 Views 0 comment Print

The issue was whether 100% of alleged bogus purchases could be disallowed despite accepted production and sales. The Tribunal held that only the embedded profit element can be taxed, not the entire purchase value.

Indexed Cost of Improvement Must Be Allowed Even for Cash Payments: ITAT Rajkot

January 21, 2026 762 Views 0 comment Print

The Tribunal examined whether cost of improvement can be denied solely due to cash payments. It ruled that genuine documentary evidence is sufficient, reducing the section 50C addition substantially.

Bogus Purchase addition restricted to 10% Despite Entry Operator Statement

January 21, 2026 996 Views 0 comment Print

The issue was whether the entire purchase amount could be added under Section 69C based solely on an entry-operator’s denial. The Tribunal ruled that since sales were accepted and books not rejected, only a 10% estimated disallowance was justified.

Assessment Set Aside for Non-Consideration of Mandatory Penalty Provisions

January 21, 2026 570 Views 0 comment Print

It was held that applying Sections 69/69A read with Section 115BBE without examining penalty under Section 271AAC justified revision. The PCIT’s direction to reframe the assessment was sustained.

TP Adjustment Based on DRI Allegations Cannot Survive After Exoneration: ITAT Mumbai

January 21, 2026 444 Views 0 comment Print

The issue was whether a transfer pricing adjustment could survive when based solely on DRI allegations later dropped. The Tribunal held that once customs authorities exonerated the assessee, the TP adjustment had no foundation and was rightly deleted.

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