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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 81 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


Non-Compliance Alone Can’t Justify ₹12 Lakh Cash Addition

December 29, 2025 219 Views 0 comment Print

Accepting the assessee’s explanation for delay and non-appearance, the Tribunal condoned the delay and set aside both lower orders. The AO was directed to re-decide the issue of cash deposits after proper hearing.

Approval for One Issue, Reopening for Another Is Legally Fatal

December 29, 2025 282 Views 0 comment Print

The ITAT ruled that section 151 approval must strictly correspond to the recorded reasons for reopening. Any factual inconsistency reflects non-application of mind and collapses the reassessment at inception.

Allotment Date Governs Stamp Value Under Section 56(2)(x)

December 29, 2025 387 Views 0 comment Print

ITAT ruled that an allotment letter constitutes a valid agreement for section 56(2)(x) where consideration and binding terms are recorded. Stamp duty value on the allotment date, not the delayed registration date, must be applied.

No Addition, No Revision: PCIT Action Fails for Want of Error and Prejudice

December 29, 2025 258 Views 0 comment Print

The Tribunal ruled that section 263 cannot be invoked merely because no addition was made during reassessment. When the AO conducts proper enquiries and accepts the explanation, revision fails for lack of error and prejudice.

NFAC Ex-Parte Order Quashed for Ignoring E-Filed Submissions

December 29, 2025 213 Views 0 comment Print

The Tribunal ruled that a statutory appellate authority cannot pass an ex-parte order after ignoring materials demonstrably available on record. The matter was restored for fresh consideration on all grounds.

Accepted Project Revenue Confirms Genuineness of Related Purchases

December 29, 2025 306 Views 0 comment Print

The Tribunal reaffirmed that once expenditure is shown to be wholly and exclusively for business, section 37(1) disallowance cannot survive. Suspicion cannot override documentary and commercial reality.

Kolkata ITAT Quashes Time-Barred Reopening for AY 2015-16

December 28, 2025 471 Views 0 comment Print

The ITAT held that reassessment initiated in July 2022 for AY 2015-16 was barred by limitation. The ruling confirms that expired cases cannot be revived under the post-2021 reassessment framework.

DGIT (Inv.) Inputs Alone Can’t Justify Reopening: ITAT

December 27, 2025 735 Views 0 comment Print

ITAT found the recorded reasons vague and non-specific, failing to even identify the nature of alleged escapement. Such mechanical reasons render the notice under section 148 void ab initio.

Entire Purchase Disallowance Rejected; 6% GP Estimation Upheld

December 27, 2025 741 Views 0 comment Print

ITAT ruled that disallowing full purchases while also taxing corresponding sales is legally unsustainable. A uniform 6% gross profit estimation on alleged non-genuine transactions was upheld as a fair and pragmatic approach.

Reassessment Falls on Threshold Error: Authority Lacked Power

December 27, 2025 519 Views 0 comment Print

The issue was whether reassessment could survive when sanction under section 151 was taken from the wrong authority. The Tribunal held that approval by the PCIT instead of the PCCIT/PDG is a fatal jurisdictional defect, invalidating the entire reassessment.

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