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Section 147

Latest Articles


Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1344 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 14922 Views 2 comments Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 6573 Views 0 comment Print

Recent Judgements of Supreme Court on Income Tax Issues

Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....

January 22, 2024 8358 Views 1 comment Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...

December 10, 2023 19590 Views 7 comments Print


Latest News


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 6936 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 12900 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 41382 Views 2 comments Print

Notices for assessment/reassessment of income of old cases

Income Tax : Under the provisions of Income-tax Act, 1961, notices for assessment/reassessment of income of old cases of more than six years fr...

August 3, 2018 1893 Views 0 comment Print

No Reopening of Assessment to be made on Audit Objections: Committee Recommends

Income Tax : One of the key sources of dispute is the existing arrangement for follow up on audit objections by Internal Audit Party and the Re...

January 20, 2016 6657 Views 0 comment Print


Latest Judiciary


Reopening Without New Material & on Mere Change of Opinion invalid

Income Tax : Gujarat High Court quashes Income Tax reassessment notice against Deepak Natvarlal Pankhiyani HUF, citing lack of fresh evidence s...

July 17, 2024 63 Views 0 comment Print

Reassessment cannot be based solely on reevaluating existing facts without new substantive material

Income Tax : PCIT Vs Farmson Pharmaceuticals Gujarat Pvt Ltd (Gujarat High Court): Reassessment cannot be solely based on a reevaluation of exi...

July 17, 2024 60 Views 0 comment Print

No re-opening of assessment on mere change of opinion without nexus with original materials

Income Tax : Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD ...

July 17, 2024 126 Views 0 comment Print

ITAT Sets Aside CIT(A)’s Order for not providing fair & reasonable opportunity

Income Tax : ITAT Raipur order on Rajesh Kumar Tiwari vs ITO. ITAT sets aside Income Tax reassessment completed without providing fair & reason...

July 17, 2024 261 Views 0 comment Print

Non-Filing of GST Return by Supplier – Assessment Reopening Validity- ITAT Mumbai Order

Income Tax : Read the detailed analysis of Karrm Infrastructure Pvt. Ltd. vs. CIT at ITAT Mumbai. Learn why ITAT ruled that non-filing of GST b...

July 17, 2024 738 Views 0 comment Print


Latest Notifications


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 8571 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 3063 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 5337 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 2934 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 14292 Views 1 comment Print


Reasons recorded for reopening of assessment must meet judicial scrutiny

December 1, 2022 2115 Views 0 comment Print

DCIT Vs Reliance Industrial Holdings Pvt Ltd (ITAT Mumbai) In the cases of the reopened assessments first and foremost one has to see the reasons recorded for reopening the assessment, as these are the reasons which give jurisdiction to the Assessing Officer for initiating, and proceedings with, the reassessment. The reasons so recorded must meet […]

AO cannot reopen assessment in absence of any tangible material showing income escapement

December 1, 2022 651 Views 0 comment Print

Sikandar And Company Vs ITO (ITAT Pune) AO has to power to reopen, provided there is tangible material to come to the conclusion that there is escapement of income from other assessment. Further, there must be reasons recorded showing live link with the formation of the belief that there is escapement of income from assessment. […]

Reopening of assessment on Mere audit opinion not valid

November 28, 2022 3336 Views 0 comment Print

Mobis India Limited Vs DCIT (Madras High Court) Hon’ble Supreme Court way back in 1979, in Indian and Eastern News Paper Society, put the issue beyond any pale of doubt by holding that the opinion on law rendered by an audit party cannot be the basis for exercising the power of reassessment. Evaluation of law […]

Reassessment without section 148 notice invalid even if assessee participated in proceedings

November 21, 2022 3297 Views 1 comment Print

Dr. Shri Gurunath Shankarappa Wachche Vs ITO (ITAT Pune) Section 292BB provides that where an assessee has appeared in any proceedings etc., it shall be deemed that any notice under any provision of this Act, has been duly served upon him in time and such assessee shall be precluded from taking any objection in any […]

Income Tax Reassessment invalid if AO failed to obtain requisite sanction u/s 151 from Pr. CIT

November 17, 2022 642 Views 0 comment Print

Income Tax Reassessment invalid if A.O having jurisdiction over the case of the assessee had failed to obtain the requisite sanction u/s 151 of the Act from the Pr. CIT qua his ‘reasons to believe’

AO cannot calculate cost of acquisition on the basis of his own assumption

November 17, 2022 1119 Views 0 comment Print

Assessing authority had passed the order beyond his jurisdiction by calculating the cost of acquisition on basis of his own assumption.

Change of opinion not base for reassessment proceedings

November 14, 2022 867 Views 0 comment Print

Delhi high court held that there was no new/ fresh material before AO to initiate reassessment proceedings, accordingly, mere change of opinion cannot form the basis for initiating reassessment proceedings

Reassessment based on same material examined in regular assessment is erred in law

November 7, 2022 1371 Views 0 comment Print

Gujarat High Court held that change of opinion on the part of the Assessing Officer acting on the same material which was examined by him in the regular assessment is erred in law.

ITAT directs AO to consider Additional Evidence related to cash deposit

November 4, 2022 711 Views 0 comment Print

Dr. BR Ambedkar Jain Kalyan Swayam Sahayata Samiti Vs ITO (ITAT Delhi) Undisputedly, in course of assessment proceeding the assessee went unrepresented, for whatever may the reason. Therefore, the assessee did not get any opportunity to explain the source of cash deposits made in the bank account with supporting evidence. However, before learned first appellate […]

Writ cannot be filed against sufficiency or adequacy of reasons for Income Tax Reassessment

November 4, 2022 414 Views 0 comment Print

Pramod Kumar Vs ACIT (Telangana High Court) HC is of the view that present is not a fit case to interdict the proceedings at the very threshold. Reasons have been assigned by the assessing officer as to why the explanation given by the petitioner could not be accepted. Certainly, such reasons given have a nexus […]

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