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Section 147

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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 87 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 111 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 93 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


Revised compounding guidelines dated 17.10.2024 cannot be given retrospective effect

December 31, 2025 252 Views 0 comment Print

Madras High Court held that compounding charges payable by petitioner as per revised Guidelines dated 17.10.2024 is unsustainable since on the date of writ order i.e. 13.04.2022, the revised guidelines was not in force. Accordingly, writ petition deserved to be allowed.

Draft Reply Challenging Reopening Based on Photocopy Evidence

December 31, 2025 903 Views 0 comment Print

The reassessment is challenged as being founded solely on an unauthenticated photocopy with no corroboration. Such material fails the “reason to believe” test and vitiates jurisdiction.

Post-2022 Reassessment Fails for Non-Compliance with Faceless Scheme

December 31, 2025 483 Views 0 comment Print

The Tribunal quashed reassessment proceedings where the section 148 notice and section 148A(d) order were issued by the JAO instead of the FAO. It reaffirmed that post-notification violations of the faceless scheme cannot be cured by participation or waiver.

No Hearing, No Finality: ITAT Reopens Ex-Parte U/s 147 Order

December 31, 2025 336 Views 0 comment Print

The appellate order was passed ex-parte under the faceless system. The Tribunal restored the appeal, directing the authority to grant three effective opportunities to the taxpayer.

Wrong Person Assessed, ITAT Quashes Rental Income Addition

December 31, 2025 378 Views 0 comment Print

The ITAT Delhi held that rental income already assessed in the hands of an HUF cannot be taxed again in the individual’s assessment. The addition was deleted to prevent double taxation of the same income.

Relative Defined, Addition Falls: ITAT Clears ₹12 Lakh Credit

December 31, 2025 375 Views 0 comment Print

The ITAT Delhi ruled that money received from a husband qualifies as an exempt gift from a relative under section 56. Such receipts cannot be treated as unexplained income in reassessment proceedings.

Cultivation Evidence Reopens Capital Gains on Land Sale

December 31, 2025 402 Views 0 comment Print

ITAT Pune admitted affidavits and satellite images showing land under cultivation, restoring the issue to AO for reassessment. Proper evidence can overturn non-agri classification for capital gains.

Section 44AD Overrides Ad-Hoc 50% Profit Estimation

December 31, 2025 927 Views 0 comment Print

ITAT Surat struck down a 50% turnover-based income estimation, applying Section 44AD to compute actual presumptive profit at 8%. Key takeaway: AO cannot inflate income without legal basis.

Reopening Quashed for Mechanical Approval Under Section 151

December 31, 2025 600 Views 0 comment Print

The Tribunal held that a bare endorsement like fit case does not amount to valid sanction. Absence of independent application of mind invalidates the entire reassessment.

Accommodation Entry Purchases Confirmed for Lack of Proof

December 31, 2025 420 Views 0 comment Print

The case involved alleged bogus purchases backed only by invoices and bank payments. The Tribunal held that without confirmations, transport evidence, or delivery proof, such purchases cannot be treated as genuine.

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