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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


Reassessment Quashed Because Notice Was Issued Beyond Limitation Period

December 25, 2025 543 Views 0 comment Print

The Tribunal held that a notice issued after three years was time-barred under section 149. Since the ₹50 lakh exception did not apply, the reassessment was invalid.

Notice Under Section 148 Invalid When Tax Issue Is Concluded in Earlier Years: ITAT Delhi

December 25, 2025 435 Views 0 comment Print

The Tribunal held that reopening an assessment on a recurring issue already decided in favour of the taxpayer by the High Court is invalid. Pending appeal before the Supreme Court cannot justify reassessment.

Section 69A Reassessment Invalid Without Proper Hearing

December 24, 2025 489 Views 0 comment Print

The issue was whether reassessment and appellate orders could stand when participation was ineffective and grounds remained undecided. The Tribunal ruled that justice required restoration of the case to the Assessing Officer.

Documented FDI Through Banking Channels Escapes Section 69

December 24, 2025 333 Views 0 comment Print

The dispute involved taxing a foreign investment as unexplained income. The Tribunal clarified that Section 69 applies only where investments are not recorded in books or the source remains unexplained.

Section 263 Quashed Because It Was Used Only for Review of a Completed Assessment

December 23, 2025 606 Views 0 comment Print

The ITAT held that revision is invalid when invoked merely to re-examine an issue already scrutinised by the Assessing Officer.

Reassessment u/s. 147 after expiry of four years tenable since all material facts not disclosed

December 23, 2025 366 Views 0 comment Print

Madras High Court held that reassessment under section 147 of the Income Tax Act after expiry of four years is sustainable in law since assessee has failed to set out truly and fully all the material facts.

Wrong Authority Approval Voids Reassessment Beyond 3 Years

December 23, 2025 651 Views 0 comment Print

The Tribunal held that approval by an incompetent authority under Section 151(ii) invalidates a reassessment issued after three years. The notice and consequential order were declared void for lack of jurisdiction.

Fair Hearing Mandatory for Section 251 Income Enhancement: ITAT Amritsar

December 23, 2025 237 Views 0 comment Print

ITAT ruled that enhancement of income under section 251 without giving the assessee a proper hearing is invalid. The appeals were remanded to CIT(A) for fresh adjudication.

Reopening Beyond 3 Years Below ₹50 Lakh Quashed

December 23, 2025 513 Views 0 comment Print

The tribunal held that reassessment beyond three years is invalid when alleged escaped income is below Rs. 50 lakh. Notices issued contrary to section 149 after the 2021 amendments were quashed for lack of jurisdiction.

Belated U/s 148 Return Costs Assessee: 1% NP Estimation Upheld

December 23, 2025 207 Views 0 comment Print

The tribunal held that non-filing of return within the due date disentitled the assessee from deduction under section 80P due to section 80AC. Consequently, lower profit claims based on accounts were rejected.

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