#Section 147
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Income Tax
Income Tax
Reopening on incoherent reasons not valid u/s 147
Income Tax
Income Tax
Reassessment u/s 147 not permissible merely on change of opinion: ITAT
Income Tax
Income Tax
Validity of reopening of assessments
Income Tax
Income Tax
Powers of the A.O. are not plenary or unbridled
Income Tax
Income Tax
AO issuing original assessment order can only initiate reopening proceedings
Income Tax
Income Tax
HC restricts remedial action on audit objection – tones down rigour of Instruction No. 9/2006
Income Tax
Income Tax
No Reopening of Assessment to be made on Audit Objections: Committee Recommends
Income Tax
Income Tax
Reassessment not valid on mere information of investigation wing as no direct nexus establishes with income escapement
Income Tax
Income Tax
Reassessment proceedings could not be declared as null and void where AO was prompted by correct information
Income Tax
Income Tax
Mere reason to believe that income has escaped assessment not sufficient to reopen assessments beyond 4 years
Income Tax
Income Tax
No new addition can be made in reopening on issue duly considered during original proceeding
Income Tax
Income Tax
Reasons to reopen assessment must be tangible & should not merely be based on Investigation wing’s report
Income Tax
Income Tax
Reassessment for taxing Royalty at higher rate due to change in opinion not valid
Income Tax
Income Tax
Re-opening being exceptional power, revenue to comply pre-requisite condition of ‘reasons’ strictly
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.
