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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


Mechanical Sanction Voids Reopening Under Section 147: ITAT Delhi

January 15, 2026 774 Views 0 comment Print

ITAT Delhi held that reassessment based on mechanical approval is invalid in law. Sanction must reflect independent application of mind by the approving authority.

Section 50C Limited to Date of Actual Transfer, Not Later Escalation

January 15, 2026 333 Views 0 comment Print

The issue was whether stamp duty value as on registration could override actual consideration received earlier. The Tribunal held that section 50C is a machinery provision and cannot be applied mechanically to post-transfer market increases.

Section 148 Notice Issued Beyond Surviving Time Invalid: ITAT Delhi

January 15, 2026 984 Views 0 comment Print

The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.

Telangana HC Quashes Section 148 Unsigned Reassessment Notice

January 15, 2026 447 Views 0 comment Print

The High Court held that a reassessment notice issued without a manual or digital signature violates Section 282A of the Income-tax Act. Such an unsigned notice is invalid in law, rendering all consequential proceedings unsustainable.

Second Reassessment Notice Cannot Cure Limitation Defect: ITAT Delhi

January 15, 2026 294 Views 0 comment Print

The assessment based on a second notice issued in July 2022 was quashed as time-barred. Once limitation had expired, subsequent notices could not revive reassessment jurisdiction.

Bogus Purchase Addition Deleted for Lack of Independent Enquiry

January 15, 2026 438 Views 0 comment Print

The Tribunal examined whether purchases could be treated as bogus solely on investigation inputs. It held that without independent verification or rebuttal of documentary evidence, the addition could not survive.

ITAT Chandigarh Remanded Unexplained Bank Credits Case with Cost for Fresh Adjudication

January 15, 2026 468 Views 0 comment Print

The Tribunal remanded additions based on excess bank credits for factual reconciliation, granting another opportunity subject to costs due to repeated non-appearance.

₹33 Cr Bank Credits: ITAT Chandigarh Sets Aside Ex Parte Reassessment for Fresh Review

January 15, 2026 318 Views 0 comment Print

The tribunal held that an ex parte assessment involving large unexplained bank credits required fresh adjudication. The matter was remanded to the Assessing Officer with one final opportunity to the assessee.

Appellate Authority Allowed to Set Aside Best-Judgment Assessment Under Amended Law

January 15, 2026 573 Views 0 comment Print

The case examined whether an appellate authority could set aside an ex-parte reassessment. The tribunal held that the amended proviso to section 251(1)(a) expressly allows such remand to ensure assessment on merits.

Reassessment Quashed: No Valid ‘Reason to Believe’ Despite Insight Portal Data – Gujarat HC

January 15, 2026 900 Views 0 comment Print

Court held that reopening of assessment based solely on vague information from Insight Portal, without a live nexus to the assessee’s records, was invalid. Reassessment notice was quashed for absence of concrete material showing income escapement.

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