#Section 147
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In absence of issue of notice U/s. 143(2) assessment U/s. 143(3) r.w. section 147 was invalid and void ab initio

Section 148 Notice in the name of non-existent firm was null and void

Re-Assessment Invalid if order sheet recording reason for reopening is unsigned

Unsigned reason cannot be treated as reasons recorded

Section 148 notice without proper sanction U/s. 151(1) is invalid

Notice U/s. 148 invalid if AO not issued notice U/s. 143(2)

HC finds no merit in Challenge to Reassessment Notice issued to Robert Vadra’s Firm

Mere Issue of 2nd notice U/s. 148 does not constitute Change of Opinion; AO can examine genuineness of share premium U/s 68

Sec 292B can’t be cure Non-application of mind in issue of Re-Assessment Notice

No reassessment merely for non reflection of ITR filed manually in IT system

Sanction for issuing a reopening notice cannot be mechanical

Penalty cannot be imposed for Bonafide omission during return filing, surfaced during Section 148/148 Assessment

Directions of JCIT or CIT cannot only be reason to believe for reopening of assessment

When the very basis of the reopening of the assessment having been eroded, notice under section 148 quashed in the case of Oracle
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.
