#Section 147
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HC quashed reassessment notice u/s 148 against Infosys Ltd.

Reassessment without notice u/s 143(2) was bad in law & cannot be revised u/s 263

Reassessment without issuance of mandatory notice u/s 143(2) was invalid

Reassessment after 4 years where assessee made true and full disclosure in original assessment was not valid

Revisionary jurisdiction cannot be exercised against Void order

Reopening in absence of fresh tangible material to form an opinion is invalid

Reopening notice based on satisfaction of some other authority is invalid

Section 148 notice without Approval of Competent Authority is invalid

Reopening invalid if reasons for same not speaks of escapement of income

S. 147 AO cannot proceed mechanically & on erroneous information supplied to him by investigation wing

Recording of reasons to believe & not reasons to suspect is pre-condition of section 147

Assessee cannot be blamed for non-disclosure if AO had such info during assessment proceeding

AO cannot do reassessment after assessment by Settlement Commission

S.147 Basic condition of ‘reason to believe’ applies even to s.143(1) intimations
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.
