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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


No Independent Inquiry, No Reopening: ITAT Strikes Down Section 147 Action

December 15, 2025 351 Views 0 comment Print

The Tribunal held that reassessment based only on the Shah Commission report, without independent material or application of mind, is invalid. Reopening beyond four years after full disclosure was quashed, nullifying additions and penalties.

Reassessment Quashed Due to Non-Compliance with Tribunal Directions

December 15, 2025 249 Views 0 comment Print

The assessee alleged denial of opportunity and improper handling of evidence. The Tribunal agreed that the appellate order was passed without due consideration of records and remand findings. The matter was sent back for fresh adjudication in accordance with law.

Accommodation Entry Allegation Rejected Due to Proper Documentation

December 15, 2025 423 Views 0 comment Print

Lenders had confirmed loans in response to statutory notices, yet additions were made. The Tribunal upheld deletion by CIT(A), stressing the importance of uncontroverted confirmations. The ruling reinforces evidentiary discipline in Section 68 cases.

Third-Party iPhone Notes Not Enough: ITAT Mumbai Deletes ₹2 Cr Addition

December 15, 2025 495 Views 0 comment Print

The Tribunal found that alleged cash payments lacked any agreement, bank trails, or confirmation from recipients, making the addition legally untenable. ITAT emphasized adherence to evidentiary standards under Section 65B and deleted the addition entirely.

Reassessment u/s. 148 quashed as name of petitioner doesn’t appear in seized material

December 15, 2025 681 Views 0 comment Print

Gujarat High Court held that reopening of assessment under section 148 of the Income Tax Act is liable to be quashed since name of the petitioner is not appearing in any of the information and documents which were found during course of search. According, petition is allowed.

Amended Reassessment Provisions Cannot Reopen Years Already Barred Under Old Law

December 15, 2025 1434 Views 0 comment Print

The Tribunal ruled that the amended reassessment law does not revive assessment years that had become time-barred under the earlier statutory provisions.

Successive Reassessment Notices Valid Under Same ‘Reasons to Believe’: Delhi HC

December 15, 2025 585 Views 0 comment Print

Delhi HC held that issuing multiple reassessment notices under Section 148 based on same ‘reasons to believe’ is valid. Petition challenging notices for A.Y. 2021-22 was dismissed.

Full Section 54F Exemption Allowed for Joint Purchase Where Assessee Funded Entire Cost: ITAT Jaipur

December 15, 2025 1119 Views 0 comment Print

The ITAT Jaipur held that joint ownership of a new property does not bar full exemption under Section 54F if the assessee funds the purchase and retains control over the asset.

Reassessment Proceedings Quashed for Ignoring Algorithm-Based Allocation Requirement

December 15, 2025 414 Views 0 comment Print

The High Court set aside reassessment proceedings after holding that notices issued by a Jurisdictional Assessing Officer violate the faceless assessment mandate under Section 151A.

Ex-Parte Order Quashed Due to Illness Preventing Timely Compliance

December 13, 2025 936 Views 0 comment Print

The tribunal ruled that ignoring a valid adjournment request vitiates ex-parte assessment and appellate orders. The is that fair opportunity is mandatory before deciding tax disputes.

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