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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 2841 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 63 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 96 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 447 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


Notice Invalid as Approval Under Section 151(ii) Was Defective: ITAT Raipur

January 6, 2026 579 Views 0 comment Print

The Tribunal held that reassessment initiated beyond three years requires approval from the Principal Chief Commissioner or Chief Commissioner. Sanction granted by the PCIT was invalid, rendering the entire reassessment void.

Form 35 Defect Curable, Dismissal Without Hearing Set Aside

January 6, 2026 363 Views 0 comment Print

The appeals were rejected without examining additions made by the Assessing Officer. The Tribunal emphasized that appellate remedies cannot be defeated by procedural technicalities and restored the cases.

Reopening Dropped as Supreme Court Concession on AY 2015-16 Is Binding

January 6, 2026 591 Views 0 comment Print

The Tribunal held that reassessment notices issued after 1 April 2021 for AY 2015-16 are legally unsustainable. Since jurisdiction itself failed under TOLA principles, the entire reassessment was quashed.

Share Gain Addition Struck Down Because It Was Outside Reopening Scope

January 6, 2026 330 Views 0 comment Print

No on-money addition was made in the cases of other co-owners of the same property. The ITAT held that the Revenue cannot adopt a contradictory stand on identical facts.

Rule of Consistency Bars On-Money Addition Against One Co-Owner

January 6, 2026 480 Views 0 comment Print

The issue was whether a buyer could be taxed for alleged cash payment based only on the seller’s admission. The Tribunal ruled that in the absence of direct or corroborative evidence, no on-money addition can be sustained in the buyer’s hands.

Notice Issued for Incorrect Year Renders Reassessment Void

January 6, 2026 330 Views 0 comment Print

The reassessment was initiated for AY 2013-14 using reasons recorded for AY 2012-13. ITAT held that reopening for the wrong year is void, causing the entire Section 147 assessment to collapse.

Agricultural Cash Deposits Not Entire Income, Only Profit Taxable

January 6, 2026 780 Views 0 comment Print

The Assessing Officer treated full bank deposits as unexplained income under section 69A. The Tribunal ruled that agricultural turnover cannot be taxed entirely and allowed only an estimated 10% addition.

ITAT Visakhapatnam Quashed Reassessment as Notice Was Issued by Wrong Authority

January 6, 2026 561 Views 0 comment Print

Gattula Lakshmi Madhavi Vs ACIT (ITAT Visakhapatnam) Central Circle Cannot Assume Reassessment Powers — Section 148 Notice Issued Outside Faceless Regime Held Void The Visakhapatnam Bench of the ITAT quashed the reassessment framed under Section 147 and consequential penalties under Sections 270A and 271AAC in the case of Gattula Lakshmi Madhavi v. ACIT, holding that […]

PF/ESI Due Date Verification Incomplete, Matter Sent Back to AO

January 6, 2026 246 Views 0 comment Print

The issue centered on employees’ PF contributions and statutory due dates post-Checkmate ruling. The ITAT held that detailed verification was still required, warranting remand.

Notice Issued Via ITBA After 01-04-2021 Triggers New Reopening Law

January 6, 2026 495 Views 0 comment Print

The issue was whether a notice dated 31-03-2021 but digitally signed on 01-04-2021 was valid. The ITAT held the notice was issued under the new regime without following section 148A, rendering reassessment void.

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