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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 81 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 108 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


DRP Route Cannot Extend Statutory Time Limit Under Section 153

December 16, 2025 648 Views 0 comment Print

The Tribunal held that a final assessment passed after the expiry of Section 153 is invalid, even if it follows DRP directions. The is that limitation under Section 153 remains mandatory and cannot be bypassed through the DRP route.

Proportionate Method Applied to Partly Accept Agricultural Income

December 16, 2025 363 Views 0 comment Print

ITAT held that disclosures in an election affidavit cannot, by themselves, justify reopening an assessment. The ruling reinforces that reassessment requires fresh tangible material and a live link to income escaping assessment.

Section 263 Revision Quashed as Penny Stock LTCG Was Examined & AO Took Plausible View

December 16, 2025 1266 Views 0 comment Print

ITAT held PCIT cannot revise assessment where penny stock LTCG transactions were fully examined and AO adopted a permissible view.

Delay before CIT(A) not fatal: ITAT restores reassessment to AO for fresh adjudication

December 16, 2025 327 Views 0 comment Print

ITAT restored the case to the Assessing Officer to examine jurisdictional defects, evidence, and applicability of section 115BBE. Technical dismissal by the appellate authority was set aside.

Reopening Beyond 4 Years Quashed for No Failure Allegation

December 16, 2025 234 Views 0 comment Print

SEO Description: The Tribunal ruled that sanction granted by merely stating as per annexure reflects no independent application of mind. Such mechanical approval violates statutory requirements. Consequently, the reassessment proceedings were set aside.

Bogus LTCG Allegation Fails Due to Lack of Proof of Manipulation

December 16, 2025 399 Views 0 comment Print

ITAT Delhi held that long-term capital gains cannot be treated as bogus merely on market suspicion or SEBI alerts without concrete evidence of manipulation.

Assessment barred by limitation as court order doesn’t contain any finding/ direction as contemplated u/s. 153(6)

December 16, 2025 384 Views 0 comment Print

Bombay High Court held that this court order doesn’t contain any ‘finding’ or ‘direction’ as contemplated by provisions of section 153(6) and consequently no order of assessment could be passed in view of bar of limitation in section 153(1) of the Income Tax Act.

ITAT Allows Additional Evidence in ₹1.11 Cr Cash Deposit Case of Widow

December 16, 2025 198 Views 0 comment Print

The dispute concerned rejection of explanation for cash deposits due to lack of documentation. The Tribunal ruled that evidence relating to sale of inherited assets was vital and must be examined afresh by the tax authorities.

Ex-Parte Order No Ground to Deny Justice: Matter Sent Back to CIT(A)

December 15, 2025 270 Views 0 comment Print

Tribunal held that non-filing of submissions or non-appearance cannot override substantive justice. CIT(A)’s order confirming additions was set aside, and matter remitted for fresh hearing.

ITAT Delhi Quashes Reassessment Over Missing Section 143(2) Notice

December 15, 2025 381 Views 0 comment Print

ITAT Delhi held that reassessment under Section 147 is invalid if notice under Section 143(2) is not issued after filing of return. Entire proceedings quashed for procedural lapse.

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