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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 69 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


Reopening on Change of Opinion Invalid: ITAT Quashes Entire Assessment

April 18, 2026 159 Views 0 comment Print

The Tribunal quashed reassessment proceedings as they were based on a mere change of opinion without any fresh tangible material. It held that re-examining already scrutinized facts does not justify reopening under section 147.

Unexplained Jewellery Investment addition Upheld as Refund Credited in Assessee’s Account

April 18, 2026 162 Views 0 comment Print

The Tribunal held that payments and delivery handled by the assessee’s PA indicated control over the transaction. The absence of evidence supporting the daughter’s role led to confirmation of addition.

Reassessment Time-Barred Despite TOLA & Ashish Agarwal: ITAT Upholds Quashing

April 18, 2026 162 Views 0 comment Print

Applying the computation method laid down in Rajeev Bansal, the Tribunal found the notice was issued late. The ruling confirms that delayed notices are void even with extended timelines.

Reassessment for AY 2015-16 Time-Barred – ITAT Quashes Entire Penny Stock Addition

April 18, 2026 156 Views 0 comment Print

ITAT Mumbai quashed reassessment for AY 2015–16 as time-barred under amended Section 149, since escaped income was below ₹50 lakh; entire penny stock addition u/s 68 was held void without examining merits.

No Penalty on Estimated Bogus Purchases: ITAT Deletes U/s 271(1)(c) Levy

April 18, 2026 189 Views 0 comment Print

The case involved penalty on disallowance of purchases treated as non-genuine and estimated at 12.5%. Tribunal ruled that estimated additions do not establish concealment, hence penalty u/s 271(1)(c) is unsustainable.

Penalty U/s 272A(1)(d) Deleted: Reasonable Cause Subsequent Compliance Accepted

April 18, 2026 267 Views 0 comment Print

The Tribunal held that penalty under Section 272A(1)(d) cannot be imposed when notices were sent to an inaccessible hacked email. It accepted that delayed compliance had a reasonable cause. The ruling emphasizes fairness in penalty proceedings.

CIT(A) Cannot Enhance on New Issue; JDA Additions & U/s 2(22)(e) Deletions Upheld

April 18, 2026 321 Views 0 comment Print

ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling clarifies that such action exceeds jurisdiction under Section 251 and must be addressed through other provisions.

ITAT Bangalore Quashes Sec 263 Revision: No Error in Valuation & No Need to Initiate Penalty

April 18, 2026 288 Views 0 comment Print

ITAT Bangalore quashed Section 263 revision, holding that AOs acceptance of FMV based on valuers report was a plausible view after enquiry and non-reference to DVO or non-initiation of penalty cannot render the order erroneous or prejudicial.

80P Deduction Allowed on Bank Interest – Bang ITAT Follows Karnataka HC, Distinguishes Totgars

April 18, 2026 288 Views 0 comment Print

ITAT Bangalore held that interest on bank deposits from operational funds of a co-operative credit society is eligible for deduction u/s 80P, as it is attributable to business activity; reliance on Totgars was held inapplicable.

Reassessment Quashed: Failure to Dispose Objections Makes 148 Proceedings Invalid- ITAT Bangalore

April 18, 2026 180 Views 0 comment Print

Reassessment quashed by ITAT Bangalore as failure to pass a speaking order on objections violated mandatory procedure under Sections 147/148, rendering entire proceedings invalid in law.

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