#Section 147
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Assessment of earlier year cannot be reopened on the basis of persuasive finding in subsequent years

Payment of Cash Salary Exceeding Rs. 20000 not allowable U/s. 40A(3)

S. 147 Supply of recorded reasons after passing reassessment order renders the reopening void

Initiation of reassessment proceedings on basis of assessment for subsequent assessment year

For reopening there must be ‘tangible material, bearing a ‘live link with formation of belief’

When there is detailed scrutiny with regard to an issue, no re-opening for mere change of opinion

Reassessment reasons to believe should be clear & not ambiguous

Furnishing of additional information by AO is not expression of opinion

Even Section 143(1) Assessment Cannot Be Reopened u/s 147 In Absence Of New Material

HC Cannot set aside reopening of assessment without giving the reason

Only Joint Commissioner or Additional Commissioner can sanction issue of Reassessment Notice

Reassessment not valid if Assessee fully & truly disclosed all material facts

Reassessment valid if income is inflated to claim higher deduction u/s. 80IA

Reopening in absence of failure on the part of assessee to disclose fully and truly all material facts is illegal
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.
