#Section 147
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ITAT Kolkata Quashed Reopening Because It Was Based on Mere Change of Opinion

Reassessment Solely on Audit Objection Invalid; Rule of Law Overrides Revenue Considerations: Delhi HC

200% Sec 270A Penalty Valid; Wrong VI-A deduction Misreporting; 270AA Immunity Denied

Reopening Beyond 4 Years Invalid; No Independent Enquiry; LTCG Penny Stock Addition u/s 68 Deleted

Sec 263 Revision Quashed as PCIT Failed to Conduct Independent Enquiry: ITAT Amritsar

Additions Based on Third-Party Ledger Deleted – Identity Not Proved & No Independent Enquiry – Revenue Appeal Dismissed; Reopening Upheld – ITAT Ahmedabad

Reopening Quashed; Labour Income Already Disclosed & 26AS TDS Reflected; Revenue Appeals Dismissed: ITAT Ahmedabad

Sec 263 Quashed; AO Probed Renuka Mata Society Credits; No Revision on Suspicion: ITAT Ahmedabad

Salary in NRE A/c Not Taxable; Foreign Employment Income Received Outside India: ITAT Ahmedabad

Sec 147 Reopening After 4 Years Invalid; Audit Objection Not Tangible; Bad Debt MAT Issue Fails: ITAT Mumbai

Reassessment Quashed: ₹50L Threshold Not Met; GP Addition Held Double Taxation; Bogus Purchase Case Won: ITAT Ahmedabad

Bogus Purchase Addition U/s 69C Deleted – Export Sales Stock Records Proved Genuineness: ITAT Mumbai

Vivad Se Vishwas Benefit Cannot Be Denied When Penalty Appeal Is Pending: Bombay HC

ITAT Rajkot Upholds Sec 263; Failure to Verify Share Capital Source of Source Makes Order Erroneous
Explore the latest Section 147 updates on TaxGuru, including relevant Income-tax Act provisions, rules, notifications, circulars, judicial decisions and compliance guidance. The coverage highlights important tax positions, procedural requirements, assessments, deductions, penalties and litigation developments to help taxpayers and professionals understand the practical implications of changes in income-tax law.
