#Section 147
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AO Can Initiate Reassessment Based on Investigation Wing Info: ITAT

Higher rate of tax in case of foreign company is not in violation of non-discrimination clause

Payment of guarantee fees to holding company for loan advanced to third party is deductible u/s. 37

Payment of guarantee fee to Gujarat Government is revenue expenditure

Give chance to Assessee to establish non-receipt of statutory notices: ITAT

ITAT Quashes Reassessment on grounds of being based on vague & non-descript reasons

Fund utilized more than prescribed limit for achieving objective allowable U/s. 11

Reopening of assessment without any fresh tangible material unsustainable

ITAT Grants Section 80IA Deduction for Port Charges, Favors Liberal Interpretation

Date of handing over of possession of new property relevant for deduction u/s. 54

Change of opinion impermissible under the grab of reopening u/s 147

Payment towards interconnectivity utility charges from Indian customers not taxable as Royalty

Reassessment can be initiated only on approval from specified authority & should not be based on change of opinion

No Addition based on mere sworn statement if not corroborated by independent evidence
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.
