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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 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


Loss-Making Co-operative Society Not Liable on Bank Deposits

December 21, 2025 267 Views 0 comment Print

The dispute involved taxing deposits despite a declared loss. The Tribunal held that when accounts show a loss, blanket addition of deposits is unsustainable.

Reassessment Quashed for Wrong Sanction Under Section 151

December 21, 2025 519 Views 0 comment Print

The Tribunal held that reassessment issued beyond three years requires approval from the PCCIT and not the PCIT. Since sanction was obtained from an incompetent authority, the entire reassessment was held void ab initio.

Profit Estimated as Safeguard; Bulk Cash Credit Addition Set Aside

December 21, 2025 327 Views 0 comment Print

The Tribunal upheld deletion of additions where receipts were linked to declared sales and no evidence of cash back was shown. Acceptance of sales negates Section 68 in the absence of proof.

ITAT Grants Last Chance in ₹2.28 Cr Unexplained Property Investment Case

December 21, 2025 234 Views 0 comment Print

ITAT Ahmedabad remanded a ₹2.28 crore unexplained property investment case to the AO, allowing the assessee one final opportunity to provide supporting documents, while imposing a ₹5,000 cost for non-compliance.

Illiteracy and Notice Errors Save ₹2.61 Cr in ITAT Delhi Ruling

December 21, 2025 309 Views 0 comment Print

ITAT Delhi overturned a ₹2.61 crore addition under sections 144/147, noting notices were sent to the wrong address and the illiterate assessee was deprived of proper hearing.

Section 153C Notice Invalid Due to Missing ₹50 Lakh Asset Satisfaction

December 21, 2025 435 Views 0 comment Print

Upholding the appellate authority, the Tribunal confirmed that jurisdiction cannot be assumed casually against a non-searched person. Statutory satisfaction requirements are mandatory, not procedural.

Revenue Appeals Fail as No Transfer of Risk and Reward Before Completion

December 21, 2025 258 Views 0 comment Print

The Tribunal held that a landowner under a JDA cannot be forced to adopt the percentage completion method merely because the developer follows it. Consistent use of the project completion method was upheld as legally valid.

Unsigned Sanction Fatal: Reassessment Proceedings Set Aside

December 21, 2025 675 Views 0 comment Print

The Tribunal held that sanction for reopening beyond four years must be granted by the specified higher authority. Approval by a Joint Commissioner was found incompetent and void. Consequently, the reassessment was struck down as without jurisdiction.

Section 144 Ex Parte Orders Invalid Without Fair Opportunity

December 20, 2025 399 Views 0 comment Print

The High Court held that an assessment completed without granting a real opportunity to respond cannot stand. Ex parte reassessment and penalty orders were therefore set aside.

Tax Assessment Set Aside for Ignoring Mandatory Legal Representative Requirement

December 20, 2025 207 Views 0 comment Print

The Court held that tax proceedings cannot continue without first determining who legally represents a deceased assessee. Orders passed without such determination were set aside.

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