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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 5676 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 1659 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 75 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 69 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 177 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 243 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 153 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 4092 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


Underreported Income & Misrepresentation: Bar to Section 270AA Application

December 28, 2023 1530 Views 0 comment Print

Explore the Kerala High Court’s judgment on IBS Software’s plea for immunity under Section 270AA of the Income Tax Act. Detailed analysis of the rejection and legal implications.

Addition u/s. 68 purely based on assumption is unsustainable in law

December 26, 2023 2196 Views 0 comment Print

ITAT Indore held that addition u/s. 68 on account of bogus long term capital gains unsustainable as the alleged transaction is not found recorded in the books of accounts including the Dmat account of the assessee. Hence, addition on the basis of assumption unsustainable.

Assessee can file Revised Form No. 10 During Reassessment: Delhi HC

December 26, 2023 948 Views 0 comment Print

Delhi High Court rules in favor of Canara Bank Relief Welfare Society, allowing the filing of revised Form 10 during reassessment proceedings. Details here.

Discovery in Later Assessments Not Grounds for Reassessment in Prior Years

December 25, 2023 1998 Views 0 comment Print

Karnataka High Court held that reassessment proceedings cannot be in the nature of review and accordingly, the material as has come to light in the assessment proceedings for the Assessment Year 2008- 2009 cannot be a sufficient ground to resort to reassessment proceedings.

Section 147 reopening notice issued in the name of dead person is invalid

December 24, 2023 4080 Views 0 comment Print

Madhya Pradesh High Court declares Section 147 notice issued in the name of deceased person for the assessment year 2018-19 as invalid, quashing all related proceedings.

Disallowance of interest on loan given to subsidiary unjustified as investment was purely for commercial expediency

December 23, 2023 1191 Views 0 comment Print

ITAT Chennai held that disallowance of interest u/s 36(1)(iii) of the Income Tax Act on loans and advances given to subsidiary company unjustified as investment in subsidiary is purely for commercial expediency.

Revisionary proceedings initiated in the name of non-existent entity is invalid

December 23, 2023 1110 Views 0 comment Print

ITAT Kolkata held that revisionary proceedings u/s. 263 initiated in the name of non-existent entity, despite the fact that private limited company was converted into LLP and the conversion was brought to the knowledge of AO, is void ab initio and invalid.

Income already disclosed in ITR: Reopening after expiry of 4 years from relevant AY is invalid

December 23, 2023 14949 Views 0 comment Print

Bombay High Court quashes reopening proceedings in Shanmukhananda Fine Arts vs Dy. Director of Income Tax, citing income already declared in the ITR. Detailed analysis.

Kerala HC Deems 24-Hour Response Time Unreasonable: Sets Aside Income Tax Assessment Order

December 20, 2023 690 Views 0 comment Print

Kerala High Court overturns Income Tax assessment order, finding 24-hour response time unfair. Detailed analysis of Aneesh vs Union of India case, implications, and court’s directives.

Order passed without mentioning DIN Number should be treated as invalid

December 19, 2023 4371 Views 0 comment Print

The Dispute Resolution Panel (DRP) order passed without Document Identification Number (DIN) number should be treated as invalid  and was contrary to the CBDT Circular No.19/2019 dated 14th August 2019 as it was clear in the body of DRP order, no DIN number was mentioned nor there was any reason of not mentioning the DIN number in order of the DRP.

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