#Section 147
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HC quashes Reassessment Orders for Contradiction in Reason for reopening

Section 148 Notice issued after expiry of 4 years, based on Addl. CITs approval, is unsustainable

Reasons recorded for reassessment cannot be substituted, added or deleted

Sufficiency or correctness of material need not be considered at the stage of issue of Section 148 notice

Reassessment Notice Issued with approval of JCIT instead of CIT is invalid

Sanction by Addl. CIT instead of PCIT not valid for Reassessment After expiry of four years

Reopening based on wrong reasons cannot be a reason to believe that income has escaped assessment

Reassessment after 4 years not valid If Assessee Made Full & True Disclosure during original assessment

HC quashes Section 148 notice for failure to record reason for issue of notice

HC quashes Reassessment Notice as reasons not existed on the date of notice

HC quashes Reassessment notice & Proceeding based on wrong premises

Reopening merely based on AIR information of Cash Deposit is not valid

Reassessment provisions framed under Finance Act, 2021 cannot be deferred by CBDT notifications: HC

Reopening based on vague & un-substantive reasoning not sustainable
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.
