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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 75 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 105 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


Wrong Sanction, Dead Reopening: Delhi ITAT Quashes 148A(d) Order for AY 2017-18

December 19, 2025 360 Views 0 comment Print

ITAT Delhi held that compliance with the statutory hierarchy under Section 151 is jurisdictional and non-negotiable. Any deviation renders the 148A(d) order, notice under Section 148, and subsequent assessment invalid.

No Search Evidence, No 153A Jurisdiction: ₹6.11 Lakh Addition Deleted

December 19, 2025 210 Views 0 comment Print

ITAT Delhi clarified that Section 153A is not meant to reassess completed years in absence of seized evidence. The ₹6.11 lakh addition was therefore held to be without jurisdiction.

Notional Interest on Interest-Free Advances Rejected Under Real Income Theory

December 19, 2025 576 Views 0 comment Print

The Tribunal reiterated that tax authorities cannot impose notional income merely because interest could have been charged. Commercial decisions on interest-free advances lie with the assessee, not the assessing officer.

Delay Condoned ≠ Merits Heard: ITAT Mumbai Remands Faceless Appeal for Fresh Adjudication

December 18, 2025 267 Views 0 comment Print

ITAT Mumbai held that condoning a delay in filing an appeal does not replace the right to present submissions on merits and remanded the case for fresh adjudication.

Addition u/s. 69A deleted as genuineness of transaction proved and shares sold as ordinary investor

December 18, 2025 432 Views 0 comment Print

ITAT Hyderabad held that addition under section 69A of the Income Tax Act as unexplained money towards bogus long term capital gains not sustained since assessee has proved the genuineness of transactions of purchase and sale of shares as ordinary investor.

₹50 Lakh Threshold Is Mandatory: ITAT Delhi Quashes Reassessment of Foreign Company as Time-Barred

December 18, 2025 540 Views 0 comment Print

LL Global Inc. Vs ACIT (ITAT Delhi) ₹50 Lakh Threshold Is Mandatory: ITAT Delhi Quashes Reassessment of Foreign Company as Time-Barred Delhi ITAT (Bench ‘D’) quashed the reassessment proceedings initiated u/s 147 r.w.s. 148, holding them to be barred by limitation under the amended law. The Tribunal noted that the notices u/s 148 were issued […]

Milk Procurement Incidental to Charitable Object; Section 11 Exemption Allowed

December 18, 2025 375 Views 0 comment Print

The tribunal held that milk procurement and sale by a charitable society were incidental to its primary object of helping small and marginal farmers, and exemption under Section 11 could not be denied.

Assessment Order Quashed as Proceedings Continued After Death Without Notice to Legal Heirs

December 18, 2025 678 Views 0 comment Print

The High Court held that an assessment order issued in the name of a dead person is a nullity. It ruled that proceedings must be continued only after issuing notice to legal representatives under Section 159.

Section 144 Assessment Quashed for Failure to Issue Mandatory Section 143(2) Notice

December 18, 2025 1230 Views 0 comment Print

The tribunal examined whether an assessment under section 144 could survive without issuance of a notice under section 143(2). It held that non-issuance of the mandatory notice rendered the assessment void ab initio.

Reassessment Quashed As AO issuing notice lacked Jurisdiction Over Non-Resident

December 18, 2025 828 Views 0 comment Print

The tribunal examined whether reassessment could be initiated by an officer lacking jurisdiction over a non-resident assessee. It held that notices issued by an incorrect authority render the entire reassessment void.

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