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Section 147

Latest Articles


Section 69A Addition Deleted Because Cross-Examination of Third-Party Witness Was Denied

Income Tax : ITAT Mumbai held that an addition under Section 69A cannot be sustained when the assessee is denied the opportunity to cross-exami...

May 13, 2026 522 Views 0 comment Print

CIT(A) cannot enhance income on issues not examined by AO: ITAT Mumbai

Income Tax : The Tribunal held that CIT(A) cannot enhance income under Section 251 on matters not considered by the Assessing Officer during as...

May 10, 2026 675 Views 0 comment Print

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 906 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 1122 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 3429 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 2361 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 4458 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 7503 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 13359 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 42870 Views 2 comments Print


Latest Judiciary


AO cannot finalize assessment before completion of DRP mechanism: Karnataka HC

Income Tax : The High Court held that issuing a demand notice along with a draft assessment order violated the mandatory procedure under Sectio...

June 9, 2026 84 Views 0 comment Print

Section 148 Notice Invalid if There Was Only Reason to Suspect, Not Reason to Believe: ITAT Mumbai

Income Tax : The Tribunal ruled that vague information and an excel sheet prepared by the Investigation Wing could not satisfy the statutory re...

June 9, 2026 96 Views 0 comment Print

No On-Money Addition based on Unsubstantiated Excel Sheets: ITAT Mumbai

Income Tax : ITAT Mumbai noted that the excel sheets relied upon by the Revenue had not been established in accordance with legal requirements ...

June 9, 2026 183 Views 0 comment Print

Builder’s Statement Lacked Corroborative Evidence – ITAT Deletes On-Money Addition

Income Tax : ITAT Mumbai held that an addition based solely on a builder's statement could not survive without evidence directly linking the as...

June 9, 2026 144 Views 0 comment Print

Reassessment Invalid as AO Relied Solely on Investigation Report without Inquiry: ITAT Delhi

Income Tax : The ITAT Delhi held that reassessment under Section 147 was invalid because the Assessing Officer merely relied on an investigatio...

June 9, 2026 90 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 5886 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 876 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 10350 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 5934 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 5943 Views 0 comment Print


Latest Posts in Section 147

AO cannot finalize assessment before completion of DRP mechanism: Karnataka HC

June 9, 2026 84 Views 0 comment Print

The High Court held that issuing a demand notice along with a draft assessment order violated the mandatory procedure under Section 144C. Since the assessment had effectively been completed at the draft stage, the reassessment orders were quashed.

Section 148 Notice Invalid if There Was Only Reason to Suspect, Not Reason to Believe: ITAT Mumbai

June 9, 2026 96 Views 0 comment Print

The Tribunal ruled that vague information and an excel sheet prepared by the Investigation Wing could not satisfy the statutory requirement of reason to believe under Section 147. It emphasized that reassessment powers cannot be exercised on mere suspicion. The notice issued under Section 148 was therefore quashed.

No On-Money Addition based on Unsubstantiated Excel Sheets: ITAT Mumbai

June 9, 2026 183 Views 0 comment Print

ITAT Mumbai noted that the excel sheets relied upon by the Revenue had not been established in accordance with legal requirements governing electronic evidence. Since the material lacked evidentiary support, the addition for Alleged On-Money Payment could not survive.

Builder’s Statement Lacked Corroborative Evidence – ITAT Deletes On-Money Addition

June 9, 2026 144 Views 0 comment Print

ITAT Mumbai held that an addition based solely on a builder’s statement could not survive without evidence directly linking the assessee to the alleged cash payment. The ₹4 lakh addition was deleted for lack of corroboration.

Reassessment Invalid as AO Relied Solely on Investigation Report without Inquiry: ITAT Delhi

June 9, 2026 90 Views 0 comment Print

The ITAT Delhi held that reassessment under Section 147 was invalid because the Assessing Officer merely relied on an investigation report without applying independent mind. The Tribunal ruled that such material did not establish a valid reason to believe that income had escaped assessment.

Builder Statements Alone Could Not Prove On-Money Payment: ITAT Mumbai

June 9, 2026 39 Views 0 comment Print

ITAT Mumbai held that an addition under Section 69 could not be sustained merely on the basis of statements recorded from representatives of the builder group. In the absence of incriminating material directly linking the assessee to the alleged cash payment, the addition of ₹31 lakh was deleted.

Penny Stock Loss Addition Deleted as Transactions Were Supported by Documentary Evidence

June 8, 2026 111 Views 0 comment Print

The Gujarat High Court upheld deletion of a loss disallowance after finding that contract notes, banking records, and trading documents supported the genuineness of the share transactions. The Court held that no substantial question of law arose.

ITAT Quashed Reassessment as AO Failed to Establish Escaped Income as Asset

June 8, 2026 216 Views 0 comment Print

ITAT Hyderabad held that reassessment beyond three years was invalid as the Assessing Officer failed to demonstrate that the alleged escaped income was represented by an asset, expenditure, or book entry as required under Section 149(1)(b). The ruling underscores the mandatory jurisdictional conditions for reopening assessments.

Deduction u/s 54F was allowable on 50 Flats received under JDA for Pre-2015 assessment year

June 8, 2026 123 Views 0 comment Print

Assessee was entitled to deduction under section 54F in respect of the entire value of all 50 residential flats receivable under the Joint Development Agreement. Prior to the amendment effective from 01.04.2015, exemption under section 54F could not be restricted merely because the investment was made in multiple residential units.

Karnataka HC Remands Reassessment Cases as SC Allowed Challenge to Retrospective Section 147A

June 8, 2026 57 Views 0 comment Print

The High Court revisited reassessment disputes after the Supreme Court took note of the retrospective insertion of Section 147A. The matters were remanded for fresh consideration with liberty to challenge the amended provision.

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