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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 5166 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


Addition u/s. 68 unsustainable as assessee duly discharged initial burden but AO failed to conduct independent inquires: ITAT Kolkata

March 20, 2024 903 Views 0 comment Print

ITAT Kolkata held that addition u/s. 68 of the Income Tax Act towards unexplained share application money is unsustainable as assessee has successfully discharged the burden of proof primarily casted upon it, however, AO failed to conduct independent inquires.

Bank Account with Social Co-operative Insufficient to Imply Accommodation Entry: ITAT

March 20, 2024 267 Views 0 comment Print

In the case of ACIT Vs Aaryavart Infrastructure Pvt. Ltd., the Income Tax Appellate Tribunal (ITAT) Ahmedabad ruled that mere maintenance of a bank account with a social co-operative bank cannot be a basis for assuming that the assessee is engaged in accommodation entries. Get insights into the case and the tribunal’s decision.

Reopening of assessment under Section 147/148 not permissible when final settlement order under Section 245D(4) has been passed

March 20, 2024 1173 Views 0 comment Print

Delve into the crucial judgment of Orchid Infrastructure Developers Pvt Ltd Vs PCIT, where the Delhi High Court ruled against reopening assessments under Section 147/148 after a final settlement order under Section 245D(4).

Goods smuggled from Foreign Origin without customs clearance in absence of reasons to believe was invalid

March 20, 2024 528 Views 0 comment Print

In the absence of “reason to believe” recorded by the authorities, revenue authorities had hopelessly failed to bring out to recordthat  the goods (here Arecanuts) imported from outside the country was without valid customs clearance.

Instructions to AO’s for initiating section 147 proceedings in I.T. e-Verification cases

March 19, 2024 9252 Views 0 comment Print

Learn how to initiate proceedings under section 147 of the IT Act in e-Verification cases. Detailed instructions for Assessing Officers provided.

Failure to substantiate identity & fund source: Kolkata ITAT Remits Matter for Re-adjudication

March 19, 2024 261 Views 0 comment Print

Kolkata ITAT remits case of Dahisar Traders Pvt Ltd vs ITO due to failure in substantiating identity & fund source, demanding re-adjudication. Full order details.

Addition which is not based on reasons for reopening is un-sustainable sans notice u/s 148

March 19, 2024 1623 Views 0 comment Print

Read the detailed analysis of Manu Stock Broking Pvt Ltd Vs ACIT case by Mumbai ITAT. Learn how additional issues impacted proceedings under section 147/148 of the Income Tax Act.

Section 50(C)(2): If taxpayer objects to valuation, AO must refer valuation to valuation officer

March 19, 2024 930 Views 0 comment Print

Mumbai ITAT orders AO to follow Sec 50C if stamp values exceed property FMV, in Rakhmabai Mhatre Mukkam Bhalgaon vs ITO case. Full text available.

Reopening of assessment u/s. 148 based on reason to suspect is unsustainable-in-law: ITAT Delhi

March 19, 2024 1641 Views 0 comment Print

ITAT Delhi held that reopening of assessment under section 148 of the Income Tax Act based on reason to suspect unsustainable as AO failed to demonstrate live link between tangible material and formation of reason to believe that income had escaped assessment.

I&B Code Proceedings and Moratorium Render Appeals Invalid

March 19, 2024 387 Views 0 comment Print

Learn about the ITAT Mumbai ruling that prohibits filing appeals during a moratorium under section 14 IBC, as seen in the case of Kaushal Silk Mills Pvt. Ltd. vs ITO.

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