#Section 147
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Reasons recorded for reopening of assessment must meet judicial scrutiny

AO cannot reopen assessment in absence of any tangible material showing income escapement

Reopening of assessment on Mere audit opinion not valid

Reassessment without section 148 notice invalid even if assessee participated in proceedings

Income Tax Reassessment invalid if AO failed to obtain requisite sanction u/s 151 from Pr. CIT

AO cannot calculate cost of acquisition on the basis of his own assumption

Change of opinion not base for reassessment proceedings

Reassessment based on same material examined in regular assessment is erred in law

ITAT directs AO to consider Additional Evidence related to cash deposit

Writ cannot be filed against sufficiency or adequacy of reasons for Income Tax Reassessment

Re-assessment proceedings against non-existent entity – HC remands matter back to AO

Disclosure before criminal investigation wing cannot be treated as disclosure’ before assessing officer in assessment

No reassessment beyond four years merely on basis of change of opinion

Section 147 assessment proceeding invalid if no valid service of notice
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.
