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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 84 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 108 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 Notice Held Valid Because SCN Period Is Excluded from Limitation: ITAT Mumbai

December 22, 2025 612 Views 0 comment Print

The dispute centered on whether a reassessment notice was time-barred and sanctioned by the correct authority. The Tribunal held that the reply period under section 148A must be excluded, bringing the notice within three years and validating the sanction.

Section 144C Can’t Extend Limitation: TP Assessment Quashed as Time-Barred

December 22, 2025 438 Views 0 comment Print

The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.

ITAT Mumbai Quashed Reassessment Notice for Being Issued Beyond Limitation Period

December 22, 2025 801 Views 0 comment Print

The issue was whether a reassessment notice issued after the prescribed time limit was valid. The Tribunal held that notices for the relevant year issued after the cut-off date were barred by limitation, rendering the reassessment void.

Section 263 Revision Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission

December 22, 2025 195 Views 0 comment Print

The ITAT held that taxing only TDS credit, while leaving the underlying undisclosed commission untaxed, is a patent error. Section 263 revision was rightly invoked to protect revenue.

Section 144B Faceless Procedure Violations Require Clear Adjudication

December 22, 2025 333 Views 0 comment Print

The dispute involved alleged non-compliance with mandatory faceless assessment procedure rendering the order non est. The ITAT held that remanding without ruling on section 144B(9) violations is impermissible.

No U/s 153A Addition, But Reassessment Power Explicitly Preserved

December 22, 2025 288 Views 0 comment Print

The ITAT corrected its earlier order after noting that the liberty to reopen completed assessments under sections 147/148 was omitted. The ruling clarifies that absence of incriminating material bars search additions but not lawful reassessment.

Entire Cash Turnover Can’t Be Taxed as Income: ITAT Rajkot

December 22, 2025 297 Views 0 comment Print

The issue was whether entire bank cash deposits could be taxed as unexplained money. The Tribunal ruled that gross receipts alone cannot be treated as income without examining business facts. Key takeaway: turnover ≠ income under section 69B.

Section 148 Notice Invalid Without PCIT/PCDG Sanction After 3 Years

December 22, 2025 567 Views 0 comment Print

The Revenue argued for exclusion of the 148A show-cause period to justify approval. The Tribunal rejected this, holding that the exclusion proviso applies only prospectively from Finance Act 2023.

Section 69A Addition Deleted After NRI Husband’s Creditworthiness Established

December 22, 2025 342 Views 0 comment Print

The issue was unexplained partner capital contribution. The ITAT held that clear proof of funding by the NRI husband with sufficient creditworthiness bars addition under section 69A.

AO Cannot Reopen Assessment Based Only on Investigation Inputs

December 22, 2025 411 Views 0 comment Print

The ITAT held that reassessment under Sections 147/148 is invalid if based solely on investigation reports, emphasizing the need for independent AO satisfaction.

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