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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 6351 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 939 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 1152 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 2511 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 41871 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 345 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 69 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 339 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 1149 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 4113 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


Communication relating to assessments, appeals, orders without DIN are null & void

August 31, 2023 1008 Views 0 comment Print

In present facts of the case, the Tribunal held that Assessment Order issued without DIN is null and void as it is in violation of CBDT Circular No. 19/2019 dated 1 4th August, 2019.

Section 148 Notice Void if AO Doesn’t examine Assessee’s Filed Return

August 31, 2023 6147 Views 0 comment Print

ITAT Delhi rules on the invalidity of a notice issued without accessing an assessee’s return, showcasing the nuances of the Income Tax Act.

CIT(A) not adjudicated issues on merit: ITAT Restores Matter to CIT(A)

August 30, 2023 543 Views 0 comment Print

ITAT Chennai reopens Carborundum Universal’s case with Deputy Commissioner over income tax deletion due to evidence gaps. Full analysis inside.

Reopening after 4 years invalid if AO fails to Establish Assessee’s Failure to Disclose Material Facts

August 29, 2023 567 Views 0 comment Print

Analysis of Bombay HC ruling in Naroli Resorts vs ACIT on reopening tax assessment after four years. Did the assessee disclose all material facts?

Development Agreement Termination Compensation Deduction allowed to One Co-Owner can’t be denied to Other

August 29, 2023 630 Views 0 comment Print

A detailed review of Raghuvirsinh Vaghela vs ITO case where ITAT Ahmedabad ruled on the validity of compensation claims in co-ownership development agreements.

ITAT Deletes Addition u/s 69 for Cash Withdrawal & Redeposit in Unsuccessful Property Deal

August 29, 2023 1683 Views 0 comment Print

ITAT Delhi reviews Inderjeet vs ITO case: Decision on withdrawals & redeposits for property deals. ITAT deletes addition under section 69.

Initiation of Re-assessment u/s 147 Requires new Tangible Material: ITAT

August 29, 2023 783 Views 0 comment Print

ITAT Ahmedabad decides on the legitimacy of re-assessment under section 147 without tangible proof of income escape. Explore the detailed verdict here.

Addition based on statements alone without any other corroborative evidence unsustainable

August 28, 2023 1746 Views 0 comment Print

ITAT Delhi held that addition primarily on the basis of statements alone and no other corroborative evidence and that too without giving assessee an opportunity to cross examine the said persons is unsustainable in law and liable to be set aside.

HC Dismisses Writ Due to Availability of Alternative Appeal Remedy

August 28, 2023 291 Views 0 comment Print

Calcutta High Court denies the writ petition challenging the assessment order u/s 147, emphasizing no objection filed in time. Alternative remedies noted.

Cash Credit Addition Deletion by CIT(A) without Verification is Unjustified

August 25, 2023 600 Views 0 comment Print

ITAT Delhi held that addition of cash credits in various bank accounts deleted by CIT(A) without verifying the persons/firm/Companies from whom the alleged amount has been credited is bad-in-law. Accordingly, matter resorted to the file of AO.

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