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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 108 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


ITAT Mumbai Quashed Reassessment Due to Invalid Notice Under Extended Limitation

January 12, 2026 810 Views 0 comment Print

The tribunal held that the reassessment notice issued by relying on COVID-era extensions was invalid due to procedural lapses. As a result, the entire reassessment and addition were set aside.

Bogus Purchase Addition Limited to Profit Element Only: ITAT Chennai

January 12, 2026 849 Views 0 comment Print

The Tribunal held that where sales are accepted and purchases are supported by documents, the entire purchase value cannot be added as bogus. Only the embedded profit element can be taxed, not the full expenditure.

Section 148 Notice Held Invalid Due to Breach of Faceless Reassessment Rules

January 12, 2026 411 Views 0 comment Print

The case addressed the legality of reopening an assessment when the notice was not issued through NFAC. Following jurisdictional High Court rulings, the Tribunal ruled that such deviation vitiates the entire reassessment process.

Section 68 Loan Addition Solely on Third-Party Statement Fails if no Independent AO Inquiry

January 12, 2026 561 Views 0 comment Print

ITAT held that a loan cannot be treated as unexplained merely on the basis of a third-party search statement. When confirmations, bank statements, and repayment evidence are on record, independent verification by the AO is mandatory.

ITAT Mumbai: Invalid Section 148 Notice Leads to Deletion of Tax Demand

January 12, 2026 741 Views 0 comment Print

With the reassessment notice quashed, the consequential assessment order and demand were automatically annulled. The ruling highlights that taxpayers cannot be burdened where initiation itself is unlawful.

Section 68 Addition Fails Without Proof of Actual Penny Stock Trades: ITAT Mumbai

January 12, 2026 936 Views 0 comment Print

The Tribunal ruled that suspicion based on penny stock lists is insufficient to sustain additions. Revenue must prove real purchase and sale transactions through demat and banking records.

Motor Car Disallowance Deleted as Ownership & Business Use Proved: ITAT Mumbai

January 12, 2026 237 Views 0 comment Print

ITAT deleted disallowance of depreciation, loan interest, and fuel expenses after finding cars were registered in the company’s name. Ad-hoc personal use disallowance without evidence was held unsustainable.

Notice by Wrong Officer Invalid, ITAT Kolkata Set Aside Entire Assessment

January 12, 2026 438 Views 0 comment Print

Since the statutory notice under section 143(2) was issued by a non-jurisdictional officer, the assessment collapsed. The ruling affirms that valid notice by the competent authority is a sine qua non.

Reassessment Quashed for Lack of Assessee-Specific Evidence in Penny Stock Case

January 12, 2026 699 Views 0 comment Print

The Tribunal held that reopening based only on generalized information about a scrip, without independent inquiry or linkage to the taxpayer, is invalid. Entire addition on alleged bogus LTCG was deleted.

Relevant Date for MAT Loss Set-Off Is Prior Year-End, Not Assessment Year-End

January 11, 2026 285 Views 0 comment Print

The Tribunal examined how brought-forward losses should be computed for MAT purposes. It held that losses as on the end of the preceding year must be considered, not figures altered during the assessment year.

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