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Section 147

Latest Articles


ITAT Mumbai Quashes Reassessment Proceedings Against Shah Rukh Khan

Income Tax : ITAT Mumbai invalidates reassessment against Shah Rukh Khan for FY 2012-13, addressing foreign tax credit claims and procedural fl...

March 8, 2025 5994 Views 0 comment Print

Assessment Proceedings under Section 147 of Income Tax Act 1961

Income Tax : Learn about Income Tax Act Section 147 assessment proceedings: reasons for reopening, notice issuance, objections, assessment proc...

February 25, 2025 1668 Views 0 comment Print

Budget 2025: Block Assessment Amendments in Income Tax Search Cases

Income Tax : Budget 2025 revises block assessment rules for search cases, covering undisclosed income, assessment procedures, penalties, and ti...

February 7, 2025 924 Views 0 comment Print

Mere Change of Opinion Not Valid ground for Income Tax Reassessment  

Income Tax : Under Section 147 of the Income Tax Act, reassessment cannot be based on a mere change of opinion by the AO. Read more on this leg...

January 16, 2025 861 Views 0 comment Print

Reassessment Post-TOLA & Finance Act 2021: Union of India v. Rajeev Bansal

Income Tax : SC clarifies reassessment notices under TOLA and Finance Act 2021 in Union of India v. Rajeev Bansal. Learn how decision impacts t...

December 16, 2024 1536 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 1152 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 2502 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 7044 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 12966 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 41871 Views 2 comments Print


Latest Judiciary


Addition u/s. 68 restricted to 0.30% of total Circular Trading Transaction: ITAT Ahmedabad

Income Tax : ITAT Ahmedabad held that CIT(A) rightly restricted disallowance on account of unexplained bank deposit and withdrawal under sectio...

March 10, 2025 63 Views 0 comment Print

Reassessment not Change of Opinion if original assessment not involve any formation of opinion

Income Tax : It was held that in the original assessment under Section 143(1), the issue related to the deed of purchase of land was not looked...

March 10, 2025 42 Views 0 comment Print

Reassessment notice issued u/s. 148 beyond six years is time barred: ITAT Mumbai

Income Tax : ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. A...

March 10, 2025 654 Views 0 comment Print

ITAT Grants 77-Year-Old Farmer Fresh Hearing After Consultant’s Misguidance

Income Tax : ITAT Surat condones a 162-day delay in appeal filing by a 77-year-old farmer, citing lack of legal guidance, and directs a fresh a...

March 9, 2025 156 Views 0 comment Print

ITAT Deletes Bogus LTCG addition for Lack of Price Rigging Evidence

Income Tax : ITAT Mumbai rules that share transactions backed by DEMAT statements cannot be treated as bogus income without concrete proof....

March 9, 2025 261 Views 0 comment Print


Latest Notifications


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 246 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 9252 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 4101 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 5511 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 3021 Views 0 comment Print


Reasons for reopening not provided – ITAT upholds quashing of order by CIT(A)

July 19, 2023 1995 Views 0 comment Print

A deep dive into the significant ruling of ITAT Mumbai in ITO Vs Asahi Infrastructure Projects Ltd case, exploring the issues related to the reopening of the assessment and non-genuine purchases, as per the guidelines set in the landmark GKN Driveshaft case.

Penalty Proceedings cannot be Challenged before Formal Order: ITAT Delhi

July 19, 2023 723 Views 0 comment Print

Delhi ITAT dismisses appeal in Tekchand Vs ITO case, stating that penalty proceedings cannot be contested unless a formal order is issued. Read the complete analysis here.

Reopening u/s 148 unsustainable as relevant income already reflected in return

July 18, 2023 1545 Views 0 comment Print

Gujarat High court held that reasons recorded while issuing notice u/s 148 was that capital gain on sale of property was not reflected in return and hence income has escaped assessment. However, factually, capital gain was already reflected in the return and hence it cannot be said that income chargeable to tax has escaped assessment and hence reopening unsustained.

Reopening of assessment before disposing of objections filed by assessee is unsustainable

July 18, 2023 1710 Views 0 comment Print

ITAT Mumbai held that reopening of assessment prior to disposing of the objections filed by the assessee is unsustainable and bad-in-law.

Enhancement by CIT(A) without providing opportunity to assessee is unsustainable

July 18, 2023 468 Views 0 comment Print

ITAT Delhi held that enhancement by CIT(A) without providing reasonable opportunity of showing cause against the proposed enhancement to the Assessee is unsustainable in law.

Grant received under Sampoorna Gramin Swarojgar Yogna is not revenue receipt

July 17, 2023 321 Views 0 comment Print

ITAT Ahmedabad held that grant received under Sampoorna Gramin Swarojgar Yogna (SGSY) from Government of Gujarat and interest earned on such grant cannot be treated as revenue receipt. Accordingly, the same is not liable to be taxed.

Reopening untenable in absence of tangible material concluding that income has escaped assessment

July 17, 2023 591 Views 0 comment Print

Bombay High Court held that reopening of assessment, in the exercise of powers under section 147 read with section 148 of the Act, without tangible material to conclude that income had escaped assessment is untenable in law.

Addition for Property Purchased from Gifts by Relatives- ITAT directs re-adjudication

July 16, 2023 1023 Views 0 comment Print

The recent ITAT Delhi decision in the case of Karamveer Singh Vs ITO emphasises the non-taxability of immovable property bought through funds gifted by relatives. Explore the case’s specifics, implications, and outcomes here.

Unverified Information: ITAT upholds quashing of Re-assessment Order

July 16, 2023 975 Views 0 comment Print

Detailed review of ITAT Delhi’s ruling in favor of the assessee, Tarik Tondon, where the reassessment order was cancelled due to lack of verification of the information which initiated the reopening.

Section 147 Assessment Invalid if Based on Cash Deposit Information Alone

July 15, 2023 4575 Views 0 comment Print

In a significant ruling, ITAT Ahmedabad deemed an assessment under Sec 147 of the Income Tax Act, based solely on cash deposit information, as invalid in the case of DineshkumarDalsangbhai Chaudhary Kankavati Society Vs ITO.

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