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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 87 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 111 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 93 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 5745 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


Director Liable for Unexplained Credits Despite Transfer to Company: ITAT Ahmedabad

December 22, 2025 153 Views 0 comment Print

ITAT Ahmedabad ruled that credit entries in the assessee’s account were correctly assessed, even though initial cash deposits belonged to a company, ensuring proper attribution of income.

Gross Interest Can’t Be Taxed Ignoring Interest Cost: Ahmedabad ITAT

December 22, 2025 144 Views 0 comment Print

Ahmedabad ITAT deleted Rs. 9.64 lakh addition under Section 69A, holding that only net interest income is taxable after deducting interest expenditure on borrowed funds.

Borrowed Satisfaction: Guwahati ITAT Quashes 147 Reopening & 68 Addition on Alleged F&O Loss

December 22, 2025 228 Views 0 comment Print

The reassessment was framed by NFAC before faceless powers under section 151A were notified. The ITAT held the entire reassessment without jurisdiction and quashed both reopening and addition.

Reopening for Section 68 but Taxing u/s 115BBC Is Jurisdictional Mismatch: Pune ITAT Quashes Reassessments

December 22, 2025 264 Views 0 comment Print

The reassessments were initiated after four years based on section 68 but concluded under section 115BBC. The ITAT held that absence of valid jurisdiction and mismatch of sections rendered the reassessments void.

Appeal Cannot Be Dismissed for Non-Appearance Without Merits Review: ITAT Chennai

December 22, 2025 312 Views 0 comment Print

The Tribunal ruled that appellate authorities must decide appeals on merits, even if the taxpayer does not appear, reinforcing the mandate of Section 250(6).

Section 148 Notice Invalid Because Dispatch Date, Not Signature Date, Determines Issuance

December 22, 2025 780 Views 0 comment Print

The ITAT held that a reassessment notice dispatched after the new law took effect must follow Section 148A, and failure to do so invalidates the entire proceedings.

Reassessment Fails Due to Wrong Use of Section 69 for Recorded Purchases with out book rejection

December 21, 2025 1344 Views 0 comment Print

ITAT held that section 69 cannot be invoked where purchases are duly recorded in books and paid through banking channels, making the reassessment unsustainable.

Cash Payment Disallowance Rejected Due to Valid 40A(3) Relief

December 21, 2025 372 Views 0 comment Print

The Tribunal held that ritualistic approval under section 153D, without application of mind, vitiates search assessments. Mandatory supervisory approval must reflect genuine examination of draft orders.

Revenue Appeal Dismissed Due to Wrong Forum Selection

December 21, 2025 195 Views 0 comment Print

The ITAT held that appeals must be filed before the correct jurisdictional bench. An appeal filed before the wrong Tribunal is liable to dismissal at the threshold.

Section 263 Invoked for Failure to Verify Source of Cash Deposits

December 21, 2025 294 Views 0 comment Print

The Tribunal upheld revision after finding that the Assessing Officer accepted explanations without proper verification. The ruling stresses that insufficient enquiry can justify action under Section 263.

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