#Section 147
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Section 148 could not be invoked in absence of any Tangible Material

Reopening U/s 147 – `Incessant Trip to Litigation’

Reopening based on mere information received from Income Tax Investigation Wing not valid

Reassessment not justified if assessee had disclosed all the material facts and provided necessary documents during assessment proceedings

Section 147: Power of Review V/s Power to Re Assess

If AO not conducted proper inquiry, the obligation to do so is on CIT(A) & ITAT

Merely Approval without application of mind not sufficient and renders reopening void

Reopening on mere ground of Cash Deposit in Bank Account not Valid

Whenever order of Re-assessment is passed, Period of Limitation will start from the date of Re-assessment order and not from Original Assessment order

For invoking reassessment proceedings, reasons has to be recorded & not conclusions

Section 153C Assessment of income of a person other than the person in whose case search has been initiated

S. 148 Approval for issue of notice for re-assessment

Reopening on ground of oversight, inadvertence or mistake is invalid

If Assessee is taxed under ‘MAT’ to ‘MAT’ – No Escapement, No Reopening
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.
