#Section 147
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Revenue Must have Tangible Material to initiate income escaping Assessment

Completion of reassessment without issue of reasons is invalid: HC

Reopening of assessment not permissible where charges on Assessee are not specific: HC

Reopening to rectify Mistake committed during Original Assessment not permissible

Re-opening of assessment not permissible on same set of materials considered in original assessment

Issue of notice u/s 143(2) before finalisation of reassessment order is mandatory

AO not empowered to initiate reassessment proceedings upon a mere change of opinion

AO is time bound to dispose of objections in response to notice u/s 148 by a speaking order: HC

Mere copy of notice given during reassessment proceedings will not meet mandatory requirement of issue & service of notice

Analysis of materials after reopening of assessment is post mortem exercise which is not permitted u/s 147 : HC

Section 147 can be invoked only if AO has reason to believe that taxable income has escaped assessment

Sec.292BB- Service of Notice- Objection raised prior to completion of reassessment is valid

Reassessment u/s 150(1) due to an appeal not permissible if it’s already time barred

Entire law on whether reopening of assessment in the absence of "fresh tangible material" is permissible reviewed
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.
