#Section 147
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Section 148 notice can be challenged before HC only after following procedure

Reopening in case of previously completed scrutiny cannot be taken up after 4 years

On mere change of opinion, the concluded assessment cannot be reopened

Assessment in the name of non-existent entity was void-ab-initio

No reassessment can be made solely on basis of statement recorded u/s 133A

Mere Change of Opinion Cannot be Basis for Re-Opening of Assessment

Non-disposal of objections to re-opening of assessment are not mere procedural lapse

Assessment proceedings cannot be conducted against HUF after partition

Important CBDT instructions on Issue of Section 147 & Section 133(6) Notice

Penalty cannot be imposed for mere Section 12A registration cancellation

Reassessment u/s 147 without any tangible material to support escapement of income not justified

Reassessment-Section 143(2) notice issued without confronting assessee with remand report is invalid

Is AIR based Notice under section 147 void ?

Jurisdictional Requirement for assumption of Power under section 148
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.
