#Section 147
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Reopening of Assessment for mere Difference in Valuation Report Not Justified

Reopening to assess Income under different head due to change of opinion is invalid

Section 148 Notice to Legal heirs after expiry of limitation period is invalid

Second Re-Assessment Notice Issued against Johnson & Johnson is Rejected by ITAT

No addition for other items if addition for reopening of reassessment not survives

Reopening of Assessment for Mere Change of Opinion is unjustified

Onus on Revenue to prove Assessee Paid Donation to College in Cash

Assessment cannot be Reopened if Assessee disclosed fully & Truly All Material Facts during Original Assessment

Reassessment not sustainable when reasons for initiation of proceedings Seized to Survive

Assessment reopening based on Wrong Appreciation of Facts is unsustainable

Issues in Respect of Reopening of Assessment

No TDS on payments to NRI for Purchase of Raw Materials

Reopening after 4 years in absence of failure of Assessee to disclose fully & truly all material facts necessary for assessment is invalid

Bogus Purchase: Addition on peal credit basis for Low Margin & Low Vat Rate Items unjustified
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.
