#Section 147
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Reassessment triggered on a change of opinion as to calculation of tax payable is invalid

AO to provide reasons to disbelieve bank statements for reopening of assessment

Reopening of assessment based on mere change of opinion is unsustainable

Forfeited amount is deductible from cost of acquisition at the time of actual transfer of asset

Disallowance of short term capital loss merely based on information from investigation wing is unsustainable

Addition without Considering Submissions of Assessee – ITAT restores matter

Addition unsustainable as identity and creditworthiness of investor company duly proved

Nothing can be added or subtracted to reasons recorded for reassessment

Addition u/s 68 untenable as AO failed to conduct independent investigation

Mere cash deposit in bank not sufficient to believe Escapement of Income

Co-owners showed capital gains of different amount – Section 148 notice invalid

HC set-aside Section 148 notice as notice issued without any new tangible material

Reassessment beyond four years is invalid if no failure to disclosure by Assessee during original assessment

Reassessment based on conjectures & surmises without any Tangible material is invalid
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.
