#Section 147
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Notice U/s. 148 notice and order on objections cannot be challenged by Writ Petition

Re-assessment proceedings based on mere bald statement that assessee has failed to make a full & true disclosure of material facts not sufficient

If no additions made on grounds of reassessment, than no addition can be made on other aspects

Reassessment cannot be challenged based on mere subsequent judgment in the case of another assessee

S. 147 Disclosure of 2G Spectrum Report not mandatory, if AO Furnished material on which he recorded his satisfaction

Explanation 3 to section 147 has no application In relation to issue cropped up subsequent to original assessment on new set of facts

Quality & lavishness of construction is not incriminating material

Re-appreciation of seized material in subsequent proceedings by the AO is unjustified

Return of income processed u/s 143(1) cannot be reassessed u/s 147 on mere change of opinion of AO

Time to be excluded in computing period of limitation for completion of assessments and reassessments

Merely applicability of sec 50C will not prove escapement of Income

Reopening on the basis of vague / uncertain information on Accommodation Entry not valid

Despite Sanction Reopening Void If Satisfaction is Recorded in a casual or routine manner

Reassessment order cannot be challenged in Writ – SC
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.
