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Section 147

Latest Articles


Legality of Second Notice under Section 148 of Income Tax Act, 1961 for Same Assessment Year

Income Tax : Explore the legality of issuing a second notice under Section 148 of the Income Tax Act, 1961 for the same assessment year. Unders...

June 6, 2024 1620 Views 0 comment Print

11 Latest Amendments in Income Tax: Analysis & Implications

Income Tax : Explore the latest changes in Income Tax laws, including extinguishment of demands, return processing, form amendments, exemptions...

March 31, 2024 15042 Views 2 comments Print

Section 153A & 153C of Income Tax Act: Analysis & Implications

Income Tax : Delve into the provisions of Income Tax Act Sections 153A & 153C, governing assessments after search or requisition. Learn from co...

February 8, 2024 7503 Views 0 comment Print

Recent Judgements of Supreme Court on Income Tax Issues

Income Tax : Explore recent Supreme Court rulings (2023) on income tax issues. Highlights of key cases, analysis, and implications....

January 22, 2024 9978 Views 2 comments Print

Section 147 to 153 Income Escaping Assessment (Reopening of Cases)

Income Tax : Learn about Section 147 to 153 Income Escaping Assessment and Reopening of Cases Under Income Tax Act, 1961. Get guidance on the p...

December 10, 2023 21357 Views 7 comments 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 546 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 1077 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 6954 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 12912 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 41454 Views 2 comments Print


Latest Judiciary


Advance tax payment provisions doesn’t apply in reassessment proceedings: ITAT Indore

Income Tax : ITAT Indore held that rejection of appeal by CIT(A) on the footing of non-payment of advance tax as required by section 249(4)(b) ...

August 17, 2024 24 Views 0 comment Print

Notice u/s. 148 to NRI without following mandatory faceless procedure unsustainable: Telangana HC

Income Tax : Telangana High Court held that notice issued u/s. 148 of the Income Tax Act must comply with the requirement of the Scheme whether...

August 17, 2024 12 Views 0 comment Print

Bogus purchase addition cannot be based on superficial inquiry: Bombay HC

Income Tax : Bombay High Court held that half-hearted approach on the part of AO to make additions on the issue of bogus purchase would not be ...

August 17, 2024 12 Views 0 comment Print

Notice u/s. 148A issued by Jurisdictional AO instead of Faceless AO liable to be quashed: Bombay HC

Income Tax : Bombay High Court held that issuance of notice under section 148A of the Income Tax Act by Jurisdictional Assessing Officer and no...

August 17, 2024 12 Views 0 comment Print

CIT needs to independently apply his mind prior to invoking revisionary provisions u/s. 263: ITAT Kolkata

Income Tax : ITAT Kolkata held that CIT has not applied his mind analytically while assuming jurisdiction for taking cognizance under section 2...

August 16, 2024 60 Views 0 comment Print


Latest Notifications


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 8745 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 3288 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 5376 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 2949 Views 0 comment Print

Case reopened in light of SC judgment in Ashish Agarwal to be completed by 31.05.2023

Income Tax : CBDT directed that cases reopened u/s 147/148A in consonance with Judgement of SC in case of UoI vs. Ashish Agarwal & CBDT instruc...

January 27, 2023 14397 Views 1 comment Print


ITAT Quashes Reassessment on Multiplicity of Errors In Reasons

August 9, 2021 1257 Views 0 comment Print

Lakhmi Chand Tejoo Mal Vs ACIT (ITAT Delhi) MULTIPLICITY OF ERRORS IN REASONS MAKE REASSESSMENT VOID  The ld. counsel for the assessee vehemently stated that 11 entries have been shown in the information and it can be seen that there are repetition of same entries/amounts and the Assessing Officer has, in fact, at para -6 […]

Reasons Based on Material Already Available on Record Invalidates Reopening

August 8, 2021 2019 Views 0 comment Print

DCIT Vs Paveljeet Singh Ruppal (ITAT Delhi) The Assessing Officer has to demonstrate from the records that there has been a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. Here in this case, the assessee has duly disclosed the factum of total secured loan, total […]

Lack of fresh tangible material invalidates reopening when details already given in regular assessment

August 8, 2021 1518 Views 0 comment Print

ACIT Vs Sahyog Infrastructure Pvt. Ltd (ITAT Delhi) Based on the above reasons recorded, notice under Section 148 of the act was issued to the assessee on 25th of June, 2013. From the above reasons recorded it is evident that all these documents were available with the ld. Assessing Officer at the time of making […]

No section 263 revision could be made for order of reassessment

August 6, 2021 6480 Views 0 comment Print

Any order of the subordinate authority which could have been considered as erroneous and prejudicial to the interest of revenue in allowing assessee’s claim of deduction under section 80IA, either due to lack of enquiry or otherwise, was the original assessment order passed under section 143(3) r.w.s. 144C and not the re-assessment order. PCIT had proceeded to revise the assessment order passed under section 143(3) r.w.s. 147 to get over the hurdle of limitation which was impermissible.

Assessment order valid despite initial section 147 notices in wrong name if revenue identifies & corrects the mistake

August 1, 2021 3066 Views 0 comment Print

Principal Officer, M/s. Vedanta Limited Vs DCIT (Madras High Court) As far as the present Writ Petition is concerned, admittedly, the notice under Section 148 was issued in a wrong name. However, close reading of the name of the Company would reveal that the first word ‘Sesa’ is not alien to the petitioner Company and […]

Section 147: Revenue to prove failure of Assessee in Full & True Disclose of All Material Facts

August 1, 2021 2667 Views 0 comment Print

PCIT Vs Superior Films Private Limited (Delhi High Court) When the assessee has filed a return u/s 139 of the Act or in response to sections 142(1) or 148 of the I.T.Act and when an assessment order u/s 143(3) or u /s 147 of the Act has already been passed then the assessee enjoys statutory […]

Reopening assessment under Section 148 without recording reasons is bad in law

July 29, 2021 3390 Views 0 comment Print

In present facts of the case, it was observed that in the absence of  reasons, the jurisdiction assumed under section 148 of the Act to reopen a completed assessment is clearly void ab initio and consequently, assessment order is bad in law.

Reassessment valid as AO formed prima facie opinion for escapement of income

July 29, 2021 912 Views 0 comment Print

Electrotherm (India) Ltd. Vs DCIT (ITAT Ahmedabad) Conclusion:  Since AO after applying his mind on information received from VAT Department arrived at the conclusion, based on the reasons to believe that income of assessee had escaped assessment. and at the time of issuing notice under section 148 AO had formed prima facie opinion for escapement […]

New scheme for re-assessment u/s 147 of the Act wef 1.4.2021

July 27, 2021 16119 Views 1 comment Print

Section 147 has been Amended vide Finance Act 2021. Information is required by AO for reopening not “Reasons to believe” If any income chargeable to tax, in the case of an assesses, has escaped assessment for any assessment year. The assessing office may, subject to the provisions of Section 148 to 153, assess or re-assess […]

Powers/Jurisdiction of Assessing Authorities for Reassessment u/s 147

July 21, 2021 2286 Views 0 comment Print

Aban Offshore Limited Vs Addl. CIT (Madras High Court) Case Summary: – Facts of the case: ♦ The Assessee, Aban Offshore Limited, engaged in providing oil field services to various oil majors for offshore exploration and production of hydrocarbons in India and abroad, is a regular Assessee in terms of the provisions of the Indian […]

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