#Section 147
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Claim Allowed in Original Assessment Cannot be Amenable to Provisions of Section 147/148

Enhancement by CIT(A) on an issue which were not part of reasons recorded for reopening the assessment are invalid

Re-Opening of Assessment u/s 147 Merely Relying upon Investigation Report Not Justified in Law

Reassessment based on Invalid Facts with no Application of Mind is Invalid

Complemented Assessment cannot be reopened U/s. 147/148 on Borrowed Satisfaction

Section 147/148 proceedings on mere investigation wing information was not valid

Section 80P deduction can be claimed while filing return in response to Section 148

Additions in reopened Assessment not valid if no addition on subject matter of reopening

No section 36(1)(iii) disallowance unless Direct Nexus between Borrowed Funds & Capital Withdrawals

Conditions Precedent for Reopening of Assessment beyond 4 Year- Section 147

Basics of Income Escaping Assessment – Section 147 – Income Tax Act, 1961

In absence of new facts reopening of already examined issue was invalid

No reopening if no failure of assessee to disclose fully & truly all material facts necessary for assessment

Validity of reopening based on Survey finding on ineligibility to claim Section 80IA Deduction
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.
