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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 5367 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 1653 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 45 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 39 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 105 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 219 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 144 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 4086 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


Reopening u/s. 148 beyond 4 years in absence of full & true disclosure of material facts unsustainable

November 9, 2023 1554 Views 0 comment Print

Gujarat High Court held that reopening of assessment under section 148 of the Income Tax Act beyond the period of four years in absence of full and true disclosure of material facts is bad in law.

Delhi HC Sets Aside Assessment Order which was based on Wrongful Allegations

November 9, 2023 1452 Views 0 comment Print

Delhi High Court sets aside an assessment order in a case involving wrongful allegations of non-current investments made in share application money of an entity.

Penalty u/s 271(1)(b) unjustified as special audit report u/s. 142(2A) submitted within extended time

November 8, 2023 462 Views 0 comment Print

ITAT Chandigarh held that imposition of penalty u/s. 271(1)(b) of the Income Tax Act unjustified as special audit completed u/s. 142(2A) and audit report submitted within the extended time limit provide by AO.

Assessment Order Under Section 144 rws 147 Invalid Without DIN: ITAT Pune

November 6, 2023 6411 Views 0 comment Print

Read about how the ITAT Pune invalidated an income tax assessment order due to the absence of a Document Identification Number (DIN) and analyzed the case’s key aspects.

Department Obligated to Provide Supporting Material for Section 148A(b) Notice

November 6, 2023 4740 Views 0 comment Print

For issuance of notice under section 148A(b), department was duty-bound and was mandatorily required to provide all material information or inquiry conducted along with supporting documents to assessee as per the provisions of Section 148A, therefore, the matter was remitted back to the respondent to supply all the relied-upon documents on the basis of which the notice had been issued and pass the order strictly in accordance with the law as mandated in the provision itself.

Reassessment without due application of mind by AO was invalid

November 6, 2023 1698 Views 0 comment Print

Re assessment notice issued under section 148 solely on basis of information received from the Kolkata Investigation Directorate that certain persons, who were based in Kolkata, had incorporated shell companies.

Bogus Purchase: ITAT Kolkata restricts addition to 5% of Bogus Purchase

November 5, 2023 2571 Views 0 comment Print

Learn about ITAT Kolkata’s decision in Sushama Industries vs. ITO for AY 2011-12, where a 5% disallowance is made on profit element of bogus purchases. Details here.

Delhi ITAT Upholds Addition for Bogus Accommodation Entry & Unexplained Commission Expense

November 5, 2023 882 Views 0 comment Print

The Delhi ITAT has upheld the addition relating to bogus accommodation entries and unexplained commission expenditure in the A and R Buildmart Pvt. Ltd. case for AY 2009-10.

ITAT Delhi dismisses reopening as same was based on change of opinion

November 5, 2023 423 Views 0 comment Print

Read the detailed analysis of the ITAT Delhi’s decision to dismiss a reopening based on a change of opinion in the case of ITO Vs Sant Singh.

Triggering of re-assessment proceedings on matter for which AO had already formed an opinion is untenable

November 4, 2023 537 Views 0 comment Print

Delhi High Court held that it is settled legal position that re-assessment proceedings under section 148 of the Income Tax Act cannot be triggered on the aspects which AO has already formed an opinion. Accordingly, notice issued u/s 148 set aside.

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