#Section 147
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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

Subsequent reversal of the legal position by judgment of Supreme Court does not authorize the department to reopen the assessment

Reassessment on the basis of subsequent decision cannot be said to be a mere change of opinion

No addition during reassessment of a particular expense which has been duly examined by the AO during Original Assessment proceedings

Reassessment not warranted on same existing set of facts, when a return and those facts already scrutinized

Mere information regarding income escapement can be considered valid for the purpose of sec. 147

Reopening not valid if reasons silent on quantum of escaped tax

Reassessment Notice for mere change of opinion is impermissible in law

Reassessment initiated on the basis of materials which were available during original assessment not valid

Initiation of Reassessment before expiry of time limit for scrutiny assessment is valid

Reopening for negligence / recklessness on the Part of A.O. not permissible
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.
