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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


Tribunal Upholds JAO Reassessment Despite Faceless Procedure Requirement

December 10, 2025 453 Views 0 comment Print

ITAT Agra held that reassessment under Section 144 by JAO is valid even though faceless procedure under Section 144B was generally applicable. The CBDT Circular of 17.03.2022 provided relaxation for cases with expiring limitation. CIT(A)’s non-est finding was set aside, ensuring compliance with procedural exceptions.

Section 68 Cannot Apply When No Credit Exists: Tribunal Rejects ₹49.98 Lakh Allegation

December 10, 2025 438 Views 0 comment Print

The Tribunal found that the AO failed to establish any bogus purchase or sale since the assessee never handled the goods and only received net surplus. Identical findings in earlier years compelled the ITAT to delete the same addition again. The takeaway is that established business patterns cannot be arbitrarily recharacterized as accommodation entries.

When Professional Negligence Meets Harsh Limitation – ITAT Steps In to Protect Assessee

December 10, 2025 378 Views 0 comment Print

The Tribunal held that the assessee cannot be penalised for mistakes of his CA and condoned a two-year delay. The matter was remanded for de novo assessment, reaffirming natural justice principles.

Commission-Based Business Proven: Tribunal Rejects Section 44AD and Upholds 5% Profit Rate

December 10, 2025 549 Views 0 comment Print

ITAT held that the assessee operated as a commission agent, not a trader, making Section 44AD inapplicable. A reasonable 5% estimation on cash deposits was upheld.

₹3.32 Cr 69A Addition Remanded as Legal Grounds Not Examined

December 10, 2025 249 Views 0 comment Print

The ITAT ruled that unresolved legal grounds—especially on reassessment validity—must first be decided by the CIT(A). The ₹3.32 crore Section 69A addition is remanded for proper adjudication.

Rural Land Claim Fails – ITAT Confirms Rs. 2.92 Cr LTCG Addition

December 10, 2025 240 Views 0 comment Print

ITAT confirmed Rs.2.92 crore long-term capital gain as the assessee failed to prove that the land sold was used for agriculture, sustaining the AO’s and CIT(A)’s orders.

Delay of 207 Days Not a Barrier as Tribunal Orders Fresh Merits-Based Hearing

December 10, 2025 318 Views 0 comment Print

The Tribunal overturned the dismissal of the appeal for lateness and allowed a full reconsideration of the issues. It emphasized that the delay must not be raised again during adjudication.

LTCG on JDA Year Reopened: Tribunal Sends Case Back for Proper Verification

December 10, 2025 135 Views 0 comment Print

ITAT Pune restored LTCG issue for AY 2015-16 to CIT(A)/NFAC, directing assessee to submit cost details & evidences, ensuring proper verification and fair adjudication.

ITAT Dismisses Rs. 24 Crore Additions Over Third-Party Documents

December 10, 2025 441 Views 0 comment Print

Additions based on decoded entries from a third-party cash book were struck down, as they did not align with the assessee’s audited books or bank statements, reinforcing the ‘dumb document’ principle.

Faceless Procedure Mandatory for Central and International taxation Charges

December 10, 2025 1566 Views 0 comment Print

The ITAT held that issuance of Section 148 notice by a Jurisdictional Assessing Officer instead of a Faceless Assessing Officer violates Section 151A, leading to quashing of the reassessment.

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