#Section 147
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Reopening based on assessment record without tangible material is unsustainable

Issue considered in order is open for revision if order is erroneous and prejudicial to interest of justice

Addition for cash deposit in bank based on reopening without application of mind deleted

Revisional jurisdiction u/s 263 not invocable as order passed by AO doesn’t satisfy twin conditions

Reassessment Notice against already Amalgamated Company is Invalid

Mere cash deposited with bank is not a prima facie belief for escapement of Income

Reassessment processing beyond 6 years is barred by limitation

Benefit of TOLA 2020 not available to first proviso to Section 149(1)(b) of Income Tax Act

Reasons recorded for reopening are to be examined on a standalone basis

Notice issued without stating basis for assumption of jurisdiction u/s 147 and 148 is unsustainable

Reassessment based on Tax Evasion Petition: HC refers matter back to AO

Initiation of re-assessment proceeding beyond four years is legally impermissible

Reassessment Notice should specify reasons for escapement of income

Section 263 cannot be invoked on issue on which AO passed order after considering detailed reply of Assessee
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.
