#Section 147
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Prima Facie some material is required not sufficiency or correctness for valid reopening u/s 147

Section 147: Assessee cannot be put to mercies of careless, casual, arbitrary or whimsical exercise of power

Section 147 assessment based on specific, relevant & reliable information is valid: SC

Non Disposal of Objections Before Concluding of Assessment With Separate Speaking Order Makes Assessment Nullity

Section 147 or 153C Assessment – Search from 3rd party premises – Unexplained Money addition under Section 69A

Reopening based on mere Shah Commission Report not Valid if no Application of Mind by AO

‘Reasons to Believe’ is Different from ‘Reasons to Suspect’: SC

Analysis of sections 147, 148, 148A, 149 and 151 of Income Tax

No reassessment merely for Loan Advancement or Non filing of ITR

Section 147 proceedings not identical to section 143(2) proceedings

Section 147 Reopening invalid if made without following mandate of Section 147,148 & 151

No reassessment if AO fails to bring new material on record

Reassessment based on Incorrect/Non-Existing reasons is Illegal & Bad in Law

Reopening of Assessment Beyond the Period of Four Years
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.
