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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 2844 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 81 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 99 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 453 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


Reassessment Void for Status Mismatch Between Notice and Order: ITAT Delhi

January 20, 2026 204 Views 0 comment Print

ITAT held that assessing an AOP without initiating reassessment proceedings against it is impermissible in law. The entire reassessment was declared non-est and additions were deleted.

ITAT Quashes ₹8.35 Cr Loan Addition u/s 68 Due to Denial of Cross-Examination

January 20, 2026 468 Views 0 comment Print

The Tribunal held that a loan repaid through banking channels cannot be treated as unexplained when identity and creditworthiness are shown. Allegations based on untested statements were rejected.

Political Donation Disallowance Set Aside for Borrowed Satisfaction & Natural Justice Violation

January 20, 2026 1167 Views 0 comment Print

The Tribunal sustained reassessment based on search information but faulted the disallowance of political donations. The key takeaway is that additions cannot rest solely on untested third-party statements without cross-examination.

Mere “Approved” Not Enough: ITAT Voids Reopening for Mechanical Sanction

January 20, 2026 381 Views 0 comment Print

The Tribunal held that reassessment was invalid as the statutory sanction under Section 151 was granted mechanically. Mere use of the word Approved does not show application of mind and vitiates the entire proceedings.

Reassessment Quashed for Mechanical Section 151 Approval: ITAT Delhi

January 20, 2026 633 Views 0 comment Print

The Tribunal held that sanction for reopening was granted mechanically and without independent application of mind, as required under Section 151. An undated and non-speaking approval vitiated the entire reassessment proceedings.

Reassessment Quashed: Undated PCIT Approval Invalid u/s 151

January 20, 2026 420 Views 0 comment Print

Failure to demonstrate a dated approval under Section 151 proved fatal to the Revenue’s case. The decision underscores strict compliance in reopening assessments.

Entire Reopening Invalid Due to Lack of Proof of Section 148 Notice Service: ITAT Delhi

January 20, 2026 249 Views 0 comment Print

The assessment was set aside as the Revenue produced no acknowledgment of service. The ruling reiterates that service of notice is foundational to reassessment.

Reassessment Quashed for Non-Issuance of Mandatory Section 143(2) Notice

January 20, 2026 555 Views 0 comment Print

The Tribunal held that reassessment under Sections 147/144B is void if no notice under Section 143(2) is issued. Acting on a return filed or adopted in response to Section 148 triggers mandatory jurisdictional compliance.

Delhi HC Slams Arbitrary Income Tax Reopening, ₹1 Lakh Cost per Case

January 20, 2026 4392 Views 0 comment Print

The court held that reopening an assessment on the same facts amounts to an impermissible change of opinion. Arbitrary second reassessment notices were quashed with ₹1 lakh costs imposed to deter harassment.

Can Penalty be Levied on Delayed Annual GST Return?

January 20, 2026 18258 Views 2 comments Print

The court held that once late fee is imposed for delayed annual return filing, a further general penalty is not permissible. Section 125 applies only where no specific penalty exists.

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