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Section 147

Latest Articles


Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1620 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 15042 Views 2 comments Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 7503 Views 0 comment Print

Recent Judgements of Supreme Court on Income Tax Issues

Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....

January 22, 2024 9978 Views 2 comments Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...

December 10, 2023 21357 Views 7 comments 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 546 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 1077 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 6954 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 12912 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 41454 Views 2 comments Print


Latest Judiciary


CIT needs to independently apply his mind prior to invoking revisionary provisions u/s. 263: ITAT Kolkata

Income Tax : ITAT Kolkata held that CIT has not applied his mind analytically while assuming jurisdiction for taking cognizance under section 2...

August 16, 2024 60 Views 0 comment Print

Passing of revisionary order u/s. 263 without giving adequate opportunity of being heard unsustainable: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that passing of revisionary order by PCIT u/s. 263 of the Income Tax Act without giving proper and adequate op...

August 15, 2024 300 Views 0 comment Print

Dismissal of appeal for non-payment of self-assessment tax unjustified as no tax was payable due to losses: ITAT Hyderabad

Income Tax : ITAT Hyderabad held that dismissal of appeal by CIT(A) on the ground of non-deposition of self-assessment tax by the assessee need...

August 13, 2024 222 Views 0 comment Print

Revision u/s. 263 set aside as order of AO not found to be erroneous and prejudicial to interest of revenue: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that order of PCIT invoking section 263 of the Income Tax Act set aside as conditions necessary for invoking S...

August 13, 2024 147 Views 0 comment Print

Section 2(14): No capital gains tax on Income proceeds from Agricultural Land

Income Tax : Notice under section 148 was issued upon assessee by AO for reassessing the cash deposit as undisclosed income, following approval...

August 13, 2024 438 Views 0 comment Print


Latest Notifications


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 8745 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 3288 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 5376 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 2949 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 14397 Views 1 comment Print


Delhi High Court dismisses 1,346 reassessment notices issued after March 31, 2021

January 7, 2022 6513 Views 0 comment Print

The Division bench of the High Court of Delhi in the case of Mon Mohan Kohli Vs Assistant Commissioner of Income Tax & Anr. quashed all reassessment notices on 15th Dec, 2021 issued by taxmen under the old regime on or after April 1, 2021, bringing in a huge relief for the taxpayers. They made […]

ITAT allows LTCG exemption on shares of ‘Unisys Software’

January 4, 2022 2052 Views 0 comment Print

Vasantlal Nyalchand Kikavat Vs DCIT (ITAT Mumbai) The case was reopened pursuant to receipt of certain information from investigation wing, Kolkata wherein it was alleged that the assessee was beneficiary of bogus Long-Term Capital gains (LTCG) by dealing in a scrip namely M/s Unisys Software & Holding Industries Ltd. (in short ‘Unisys’). Accordingly, the case […]

No reassessment in absence of failure on part of assessee to fully & truly disclose all material facts

January 3, 2022 1842 Views 0 comment Print

District Co-operative Central Bank Ltd. Vs ACIT (ITAT Bengalore) Conclusion: Reassessment beyond four years was not valid in the absence of failure on part of assessee to fully and truly disclose all material facts necessary for assessment. Held: Assessee claimed deduction of Rs.3,50,00,000/- u/s 36(1)(viia). However, assessee debited only Rs.3,00,00,000/- to the profit and loss […]

CIT sanction without application of judicious mind is invalid- section 151

December 22, 2021 3477 Views 0 comment Print

Since in the present case, the sanction was accorded by the ld. CIT in a purely mechanical manner without application of judicious mind, therefore, the sanction so accorded cannot be held to be a proper and valid sanction within the meaning of Section 151 of the Act

HC quashes Notice for Reopening of Assessment as reason for reopening not state that there was any failure on the part of petitioner

December 17, 2021 1749 Views 0 comment Print

Coca-Cola India Private Limited Vs DCIT (Bombay High Court) Revenue relied upon a Bombay HC judgment in Crompton Greaves Ltd. V/s. ACIT to submit that even if the reason for reopening does not specifically state that there was any failure on the part of petitioner to disclose fully and truly all material facts necessary for […]

Reopening of Assessment Not Permissible for Change of Opinion

December 15, 2021 1518 Views 0 comment Print

Skoda Auto Volkswagen India Private Limited Vs ACIT (Bombay High Court) Petitioner had in its annual report mentioned about the technical know how fee, royalty and technical assistance fee that it had paid to Skoda Auto a.s. and Volks Wagen AG. Petitioner had also filed Form 3CEB in which it had disclosed about details and […]

Addition based on mere Third Party statement without granting Cross-Examination deleted

December 13, 2021 7545 Views 0 comment Print

Vijayshree Food Products P. Ltd. Vs ACIT (ITAT Delhi) The reopening has been challenged by the assessee stating that initiation of proceedings u/s 147 of the income tax act is solely on the basis of the unverified, on rectified, unsubstantiated and unconfirmed statement of Mr Malu. It is further the claim of the assessee that […]

Bogus LTCG- HC upheld Reassessment notice after expiry of 4 Years

December 10, 2021 1965 Views 0 comment Print

Kaushaliya Sampatlal Dudani Vs ITO (Gujarat High Court) A bare perusal of the reasons recorded and further clarification of the information made by the revenue by way of affidavit in reply would make it clear that, the company Tuni Textile Ltd., was used in providing bogus accommodation entries of long term capital gain by certain […]

Mere disclosure of bogus transaction not sufficient, reopening of assessment sustainable

December 9, 2021 4569 Views 0 comment Print

After framing of the assessment made under Section 143(3) of the Act, tangible material came into the hands of the AO through the investigation wing and upon perusal of the same, he made independent inquiries and applied his mind and upon due satisfaction, he formed an opinion that, the income has escaped assessment.

HC Quashes reopening notice issued merely based on change of opinion

December 5, 2021 1263 Views 0 comment Print

Rama Devi Sabat Vs DCIT (Orissa High Court) Contending that the initiation of the reassessment proceedings was based merely on a change of opinion, the present petition has been filed. A perusal of the reasons mentioned above for reopening of the assessment reveals that there was no new material available with department. It is also […]

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