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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 5649 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 1656 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 909 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 2490 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


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 66 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 69 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 165 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 228 Views 0 comment Print

Retrospective Amendment Doesn’t Justify Reassessment Beyond Four Years

Income Tax : Bombay High Court sets aside IT reassessment against Oxford University Press, ruling no failure to disclose material facts for reo...

March 8, 2025 153 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 4089 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


Issuance of Notice & Reassessment Beyond Six Years Barred by Limitation

May 31, 2023 2025 Views 1 comment Print

Calcutta High Court has recently ruled that the issuance of notice and initiation of reassessment beyond six years is barred by limitation

Power of reopening an assessment is a ‘power’ which should be exercised with adequate reason

May 30, 2023 1233 Views 0 comment Print

HC set aside SCN issued under Section 148A(b) & consequential orders on the grounds that the opportunity of being heard provided at first instance should be an effective opportunity, since, the power of reopening an assessment is a ‘power’ which should be exercised with adequate reason.

Penalty u/s 271(1)(c) not imposable when income assessed on estimate basis

May 29, 2023 8898 Views 0 comment Print

ITAT Delhi held that penalty under section 271(1)(c) of the Income Tax Act not imposable when income is assessed on estimate basis and accordingly additions are made therein on estimate basis.

Conundrum Surrounding Limitation Period For Issuance of Re-Assessment Notices Under The Income Tax Act, 1961

May 29, 2023 13068 Views 1 comment Print

The scope of reopening assessments under the Income Tax Act, 1961 (IT Act) remains unclear, despite several reformative changes introduced by the Parliament through the Finance Act, 2021.

FMV determined by registered valuer after considering relevant factors cannot be ignored

May 29, 2023 1866 Views 0 comment Print

ITAT Surat held that fair market value (FMV) by the registered valuers is determined after taking into account all the relevant factors like size, shape, situation, location, utility, future potentiality, etc. accordingly, the same cannot be ignore.

Initiation of reassessment in the name of non-existent amalgamated company is without jurisdiction

May 27, 2023 585 Views 0 comment Print

ITAT Kolkata held that reassessment proceeding initiated in the name of non­existent amalgamated company is without jurisdiction, void ab initio and is liable to be annulled.

Reassessment merely based on information received from investigation wing is bad in law

May 25, 2023 3348 Views 0 comment Print

ITAT Delhi held that reopening of assessment proceedings merely on the basis of information received from the investigation wing is invalid and bad in law and hence liable to be quashed.

Non-compliance due to receipt of notice in SPAM folder is sufficient cause for condonation of delay

May 24, 2023 2169 Views 0 comment Print

ITAT Jaipur held that non-compliance due to receipt of notice in SPAM folder is sufficient cause shown for the delay. Accordingly, delay of 223 days in filing of an appeal condoned.

Section 45(5A) inserted vide Finance Act 2017 doesn’t have retrospective effect

May 23, 2023 2538 Views 0 comment Print

Patna High Court held that sub-section (5A) of section 45 inserted by way of an amendment in the Finance Act, 2017, expressly stated to be effective from 01.04.2018 cannot be treated as retrospective.

Disallowance u/s 36(1)(iii) unsustainable as advance given during normal course of business

May 21, 2023 1986 Views 0 comment Print

ACIT Vs Hotel Ishika (ITAT Raipur) ITAT Raipur held that the interest expenditure corresponding to the advances that was given in the normal course of business could not have been disallowed under section 36(1)(iii) of the Income Tax Act. Facts- Post completion of original assessment, as is discernible from record, the A.O on the basis […]

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