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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 5814 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 1665 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 921 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 2499 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


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 420 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 126 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 156 Views 0 comment Print

ITAT Surat Directs Re-examination of Tax on Gift from HUF

Income Tax : ITAT Surat remands case to CIT(A) for fresh adjudication on HUF gift taxability under Section 56(2)(vii) of the Income Tax Act, ci...

March 9, 2025 231 Views 0 comment Print

Search Incriminating Material Requires Proceedings Under Section 153C, Not 147/148

Income Tax : ITAT Jaipur rules that when search finds incriminating material, proceedings must be under Section 153C, not 147/148. Read case de...

March 8, 2025 255 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


Addition towards trading in penny stock sustained for lack of assistance during appeal proceedings

June 27, 2023 507 Views 0 comment Print

ITAT Ahmedabad sustained the addition on account of trading in penny stock of shell company as assessee failed to attain personal hearing inspite of various occasion.

Assessee’s Non-Participation in Reassessment Proceedings makes Section 292BB Inapplicable

June 25, 2023 408 Views 0 comment Print

The ITAT Delhi quashed a notice issued to a deceased person, stating that Section 292BB of the Income Tax Act is inapplicable if the assessee didn’t participate in reassessment proceedings.

Addition invoking section 56(2)(vii)(b) unsustained as stamp duty value less than agreement value

June 24, 2023 2769 Views 0 comment Print

ITAT Mumbai held that as conditions in second proviso to section 56(2)(vii)(b) satisfied, stamp duty as on the date of agreement would be compared with agreement value. Accordingly, since the stamp duty value is less than the agreement value, addition unsustainable.

Addition u/s 69A unsustainable as source of loan transaction duly explained

June 24, 2023 6522 Views 0 comment Print

ITAT Mumbai held that once the transaction is duly recorded in the books of accounts and due explanation with regard to source of loan transaction is provided, addition u/s 69A towards unexplained money unsustainable.

Re-assessment notice time barred as conditions prescribed under 1st proviso to section 147 not complied

June 23, 2023 1461 Views 0 comment Print

ITAT Delhi held that the re­assessment notice issued under Section 148 is clearly time barred owing to non compliance conditions prescribed on 1st proviso to Section 147 of the Act. Accordingly, re-assessment proceeding is illegal and without jurisdiction.

Addition in bogus purchase transaction reduced on pro-rata basis

June 22, 2023 1200 Views 0 comment Print

ITAT Raipur held that addition in case of bogus purchase transaction restricted to the extent of the difference between the gross profit of genuine purchases transactions and gross profit of bogus purchases transactions.

Amount not taxable under ‘capital gain’ as there is no transfer of right, title or interest in property

June 22, 2023 2187 Views 0 comment Print

ITAT Mumbai held that amount under the head ‘capital gain’ not taxable as there is no transfer of any right, title, or interest in the property.

Delhi High Court Cancels Reassessment for Income Below Statutory Limit

June 22, 2023 1131 Views 0 comment Print

Discover the recent ruling by the Delhi High Court quashing time-barred reassessment proceedings for escaped income below the mandatory monetary threshold.

HC dismisses Writ due to detailed Section 147 order with extensive reasons

June 21, 2023 7344 Views 0 comment Print

Court dismissed the writ petition arguing that the impugned assessment order under Section 147 of the Act was, in fact, an appealable order, and had been passed providing extensive reasons.

Issue of notice u/s 148 against deceased assessee is null in the eyes of law

June 20, 2023 6765 Views 0 comment Print

ITAT Mumbai held that issuance of notice for re-opening of assessment under section 148 of the Income Tax Act against the deceased assessee is null in the eyes of law.

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