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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 75 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 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


AY 2015-16 Reassessment Void as Post-2021 Notices Are Time-Barred

January 6, 2026 552 Views 0 comment Print

The AO added ₹1 crore based on alleged cash receipts from third-party material. The Tribunal held the reopening itself was invalid, so the addition could not survive.

Section 148 Notices for AY 2015-16 Invalid Under New Regime

January 6, 2026 1197 Views 0 comment Print

The AO issued reassessment notices during the post-Ashish Agrawal transition phase. Applying later Supreme Court law, the ITAT held AY 2015-16 is beyond the permissible reopening period.

Cash Deposits Added as Unexplained Income Because Sales Bills Were Not Examined

January 6, 2026 624 Views 0 comment Print

The tribunal held that where key sales and purchase documents were not examined at assessment, the issue must be remanded. Cash deposit additions were set aside for fresh verification by the Assessing Officer.

No Proof of On-Money, ₹1.52 Cr Buyer Addition Deleted

January 6, 2026 339 Views 0 comment Print

No incriminating material showed payment over the registered consideration. The tribunal held that without independent evidence, the ₹1.52 Cr addition could not be sustained.

Post-2022 Reassessment Fails for Ignoring Faceless Procedure

January 6, 2026 777 Views 0 comment Print

The case examined whether reassessment proceedings could survive when issued outside the faceless mechanism. The ruling confirms that non-compliance with the faceless scheme is a fatal jurisdictional defect.

Reassessment Quashed Because Section 148 Notice Was Time-Barred

January 5, 2026 927 Views 0 comment Print

The issue was whether a reassessment notice issued in July 2022 for AY 2015-16 was valid. The Tribunal held it to be barred by limitation, rendering the entire reassessment void.

₹1 Crore Commission Addition Rejected for Mere Suspicion

January 5, 2026 609 Views 0 comment Print

The assessing officer estimated commission income by assuming investments were accommodation entries. The tribunal confirmed that additions based on assumptions, without concrete evidence, are legally unsustainable.

Assessment Quashed for Ignoring Binding DRP Directions

January 5, 2026 435 Views 0 comment Print

The core issue was whether an assessment can survive when DRP directions are disregarded. The Tribunal held that failure to follow binding DRP instructions renders the assessment void ab initio.

Share Capital Addition u/s 68 Fails in Pre-2013 Years: Kolkata ITAT Deletes ₹4.28 Cr

January 5, 2026 264 Views 0 comment Print

The issue was whether the company could be asked to explain the source of shareholders funds for a pre-2013 year. The Tribunal held that the proviso to section 68 is prospective, making the addition unsustainable.

Reassessment Quashed Because Notices Were Issued to a Dead Person

January 5, 2026 375 Views 0 comment Print

The issue was whether reassessment can continue when all notices are issued in the name of a deceased assessee. The Tribunal held such proceedings void ab initio, as jurisdiction ceases upon death.

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