#Section 147
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Addition for unexplained cash deposit by CIT(A) justified -ITAT Delhi

HC quashes Section 148 Notice issued without prior administrative approval of PCIT

No Reopening On Borrowed Satisfaction Without Bringing Tangible Material on Record

No Change of Opinion if facts related to deemed consideration U/s. 50C been overlooked

No Reopening on Borrowed Satisfaction when view was already taken by AO

Reopening of assessment invalid if based on “change of opinion”

Section 147: AO must act based on ‘reasons to believe’ & not on ‘reasons to suspect’

Mere Vague Air Information of Cash Deposit Not Sufficient to believe Escapement of Income

Reassessment justified in case there was enough material before AO

Assessment based on unsigned section 148 notice is bad in law

Reopening without bringing any fresh material on record is invalid

Reopening based on investigation wing info without independent application of mind by AO was invalid

Reopening on Estimate Based on Vague Information Is Not Valid

ITAT quashes reopening of assessment as AO not alleged that Assessee failed to disclose material facts during Original Assessment
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.
