#Section 147
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Reopening proceedings without communicating reasons for reopening to assessee not valid

S. 148 Notice issued in the name of Company due to clerical mistake which already gets converted into LLP is valid

Section 147 Approval to reopen with mere words “Yes. I am satisfied” not valid

Re-Assessment notice after 4 years without Approval of CIT or CCIT is Invalid: Delhi HC

Reassessment merely based on allegation that appellant has PE in India cannot be sustained

Service of Section 148 Notice to CA of Assessee is not service at all

Mere change of opinion on same facts and law does not justify a reassessment

s. 292B cannot save Assessment order passed without Notice u/s 143(2)

Non issue of notice U/s. 143(2) invalidates reassessment

Deeming fiction U/s. 292BB not applicable on failure to issue notice U/s. 143(2) within specified period

Reopening of assessment maintainable on reasons recorded for reopening

Reopening after 4 years with approval of DIT instead of JCIT is invalid

Reassessment merely on DIT (Investigation) information is bad under law

No penalty on income on which tax been paid before notice U/s. 148 & disclosed later
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.
