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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 75 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


Delay in Appeal Filing Must Yield to Substantial Justice

January 17, 2026 591 Views 0 comment Print

The tribunal held that refusal to condone delay defeats substantial justice when reasonable cause exists. Delay was directed to be condoned and appeal heard on merits.

Accommodation Entry Income Cut to 1.5% in Bank Routing Case

January 17, 2026 498 Views 0 comment Print

Where funds were merely routed through the assessee’s bank account, the tribunal ruled that only commission income is taxable. The earlier 2% estimation was reduced to 1.5% as more reasonable.

Wrong Valuation Report Leads to Capital Gains Addition

January 17, 2026 756 Views 0 comment Print

Capital gains were computed without allowing improvement costs due to submission of an incorrect valuation report. The Tribunal held that a bona fide mistake justified reconsideration with correct evidence.

Delay Excused Where Notices Never Reached the Assessee

January 17, 2026 354 Views 0 comment Print

The core issue was whether lack of knowledge of proceedings justified late appeals. The Tribunal held that notices sent to an inaccessible email amounted to sufficient cause. The decision emphasizes procedural fairness.

Audit Penalty Set Aside Due to Bona Fide Cause for Delay

January 17, 2026 705 Views 0 comment Print

The dispute concerned late filing of an audit report triggering penalty under section 271B. The Tribunal accepted personal hardship and first-year audit obligation as reasonable cause under section 273B. The decision reinforces relief where delay is genuine and explained.

Stamp Duty Addition Deleted for Lack of Evidence of Claim

January 16, 2026 390 Views 0 comment Print

The Assessing Officer alleged incorrect claim of stamp duty expenditure without identifying any such entry in the accounts. The Tribunal deleted the addition, holding it to be based on presumption.

Ex-Parte LTCG Order Set Aside for Fresh, Fair Computation

January 16, 2026 402 Views 0 comment Print

The ITAT restored an ex-parte assessment where LTCG was added mechanically without hearing the taxpayer. The ruling reinforces that denial of natural justice vitiates capital gains assessments.

Disallowance on alleged fictitious loss without incriminating material cannot be sustained

January 16, 2026 429 Views 0 comment Print

ITAT Mumbai held that disallowance on account alleged fictitious trading loss in absence of any direct incriminating material is not sustainable. Accordingly, CIT(A) rightly deleted the disallowance and allowed the appeal of the assessee. Thus, the present appeal by revenue is dismissed.

Ex-Parte Appeal Dismissal Set Aside for Lack of Reasoned Order

January 16, 2026 333 Views 0 comment Print

The issue was whether the appellate authority could dismiss an appeal ex-parte without giving detailed reasons. The Tribunal held that a non-speaking order violates section 250(6) and restored the appeal for fresh adjudication.

Reassessment Quashed as JAO Lacked Jurisdiction After Faceless Scheme

January 16, 2026 1812 Views 0 comment Print

The issue was whether reassessment notices could be issued by a jurisdictional officer after the faceless reassessment scheme became mandatory. The Tribunal held that such notices are void, rendering the entire reassessment unsustainable.

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