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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 6408 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 1677 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 960 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 864 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 1161 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 2517 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 41874 Views 2 comments Print


Latest Judiciary


IT Reassessment Notice Beyond TOLA’s Limitation Period Invalid: ITAT Mumbai

Income Tax : ITAT Mumbai quashes reassessment against CLE Private Limited, ruling notice issued beyond TOLA's limitation period is invalid....

March 11, 2025 387 Views 0 comment Print

Reassessment Beyond 4 Years Requires failure to disclose material facts: Bombay HC

Income Tax : Learn about the Bombay High Court's decision in Crystal Pride Developers vs ACIT regarding reassessment beyond 4 years under Secti...

March 11, 2025 81 Views 0 comment Print

Addition u/s. 68 restricted to 0.30% of total Circular Trading Transaction: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that CIT(A) rightly restricted disallowance on account of unexplained bank deposit and withdrawal under sectio...

March 10, 2025 408 Views 0 comment Print

Reassessment not Change of Opinion if original assessment not involve any formation of opinion

Income Tax : It was held that in the original assessment under Section 143(1), the issue related to the deed of purchase of land was not looked...

March 10, 2025 57 Views 0 comment Print

Reassessment notice issued u/s. 148 beyond six years is time barred: ITAT Mumbai

Income Tax : ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. A...

March 10, 2025 2466 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 9255 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 4116 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 5514 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


No Addition based on mere sworn statement if not corroborated by independent evidence

September 7, 2023 6981 Views 0 comment Print

Analyzing ITAT Bangalore’s ruling in Yashaswi Fish Meal and Oil Company Vs DCIT, exploring the role of sworn statements in tax assessments.

Deduction of cost of land with expenses allowable from sale consideration

September 6, 2023 4329 Views 0 comment Print

ITAT Indore held that deduction of cost of land with expenses for exploitation on land duly allowable from the sale consideration before charging tax on the same.

Revision u/s 263 justified as AO grossly failed to verify nature and source of transaction

September 5, 2023 546 Views 0 comment Print

ITAT Raipur held that revisionary jurisdiction under section 263 of the Income Tax Act rightly invoked as there is a gross failure on the part of the A.O to verify the nature and source of the cash deposits.

Addition towards unexplained credit not sustained as source of credit duly explained

September 5, 2023 531 Views 0 comment Print

ITAT Ahmedabad held that addition u/s 68 of the Income Tax Act towards unexplained credit unsustainable as the assessee has been able to reasonably explain the source of gift from his mother.

Revision u/s 263 for non-invocation of section 115BBE on addition u/s 68 towards unexplained sundry creditors justified

September 5, 2023 1185 Views 0 comment Print

ITAT Rajkot held that invocation of revisionary jurisdiction u/s 263 non-invocation of section 115BBE of the Act on the addition made on account of unexplained sundry creditors u/s. 68 of the Act is duly justifiable.

Issuance of notice to demerged company is invalid

September 4, 2023 684 Views 0 comment Print

ITAT Indore held that issuance of notice under section 148 of the Income Tax Act to the demerged company i.e. non-existent company is invalid and liable to be quashed.

Interest payment on cash loan covered u/s 69C as unexplained expenditure

September 4, 2023 984 Views 0 comment Print

Held that payment of interest on cash loan falls within the ambit of unexplained expenditure within the meaning of Section 69C of the Income Tax Act.

Reopening of assessment without tangible material is invalid

September 4, 2023 1122 Views 0 comment Print

ITAT Ahmedabad held that reopening of assessment u/s. 147 of the Income Tax Act after four years without any tangible material amounts to change of opinion and according the same is invalid and liable to be quashed.

Cash Payment exceeding prescribed limit towards purchase of land disallowed as per section 40A(3)

September 4, 2023 2103 Views 0 comment Print

ITAT Ahmedabad held that payment of cash towards purchase of land exceeding the prescribed limit is duly disallowed under section 40A(3) of the Income Tax Act.

Reopening of assessment after full and true disclosure of material facts unsustainable

September 3, 2023 2064 Views 0 comment Print

Bombay High Court held that reopening of assessment u/s 147 of the Income Tax Act unsustainable as the assessee has fully and truly disclosed all the material facts.

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