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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 5208 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 42 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 36 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 87 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 141 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 4083 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


Assessment Reopening Limited to Four Years if there was Full Disclosure by Assessee

May 5, 2024 954 Views 0 comment Print

Mumbai ITAT rules in Lalita Troy Caeiro Vs ITO case that assessment can’t be reopened beyond 4 years if there’s full disclosure by assessee. Detailed analysis and conclusion provided.

Non-payment of tax before first appeal filing not fatal if appellant fulfills tax obligation later

May 5, 2024 774 Views 0 comment Print

in terms of section 249(4)(a) of the Act, stipulation as to payment of tax ante filing of first appeal is only directory and not mandatory, where appeal is filed without payment of tax but subsequently required amount of tax is paid, appeal shall be admitted on making payment of tax and taken up for hearing on merits.

Reassessment cannot be based solely on reasons borrowed from other departments or reports

May 5, 2024 1593 Views 0 comment Print

In case of Balaji Mines And Minerals Pvt Ltd vs ACIT, Bombay High Court ruled that reassessment cannot be based solely on reasons borrowed from other departments or reports, such as Justice M.B. Shah Commission Report.

Assessee eligible for vacancy allowance under section 23(1)(c) for vacant commercial units

May 5, 2024 783 Views 0 comment Print

Explore the detailed analysis of Mack Star Marketing Private Limited Vs National Faceless Appeal Centre Delhi regarding taxing unsold flats in real estate business, applicable from AY 2018-19. ITAT deletes notional rent addition for AY 2014-15.

Contractor’s statement alone insufficient to establish a transaction as benami

May 5, 2024 591 Views 0 comment Print

Allahabad High Court quashes benami transaction proceedings in Smt. Meera Pandey Vs Union of India case, stating contractor’s statement alone insufficient. Read full judgment.

Section 148 Notice Invalid; Should Have Followed Faceless Regime: Section 151A

May 3, 2024 22170 Views 1 comment Print

Detailed analysis of Bombay High Court’s ruling on Hexaware Technologies Ltd vs ACIT. Invalid notice under Section 148 scrutinized. Time limitation, violation of CBDT Circular, faceless regime, jurisdictional conditions, change of opinion, and more explored.

Addition u/s 68 was justified as assessee’s failed to establish genuineness of transaction with cogent and credible evidence

May 2, 2024 897 Views 0 comment Print

Assessee had miserably failed to establish genuineness of the transaction by cogent and credible evidence and that the investments made in its share capital were genuine.

Section 143(1) Assessment cannot be Reopened on Mere Suspicion: Bombay HC

April 28, 2024 10080 Views 0 comment Print

Explore how the Bombay High Court ruled against reopening Section 143(1) assessments without valid reasons, safeguarding taxpayers’ rights. Detailed analysis and implications.

Conditions for Section 153A Reassessment notice Issuance after 6 Years

April 28, 2024 1617 Views 0 comment Print

Discover the conditions for issuance of a reassessment notice u/s 153A beyond six years & explore the detailed analysis of ACIT Vs Goldstone Cements Ltd. (ITAT Kolkata) case.

One assessment order per assessee per assessment year should prevail unless annulled or set aside

April 19, 2024 1200 Views 0 comment Print

The court’s deliberation highlights the absence of any challenge to the initial re-assessment order or its revision by the Commissioner. Furthermore, the judgment underscores the principle that one assessment order per assessee per assessment year should prevail unless annulled or set aside by a competent authority or court.

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