#Section 147
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Reassessment on the basis of information received under treaty is valid

Reopening on the basis of information of accommodation entries justified

No change of opinion if AO not examined or applied his mind on a particular issue-HC

Reopening on the ground on which AO already held detailed discussion during original Assessment is not valid

Reopening based on Second thought on same material not valid – SC

Reversal of law by Supreme Court does not justify reopening

Reopening on the basis of approval from CIT instead of JCIT/Addl. CIT is not valid

Reopeing of Assessment to verify compliance with provisions amended in future is invalid

Re-assessment held to be void if AO has not analysed in detail the reasons of reopening

Assessment cannot be reopened u/s 147 in absence of tangible material

Re-opening of assessment for change of opinion not valid – SC

Section 147 cannot be invoked for amendment with retrospective effect

Fishing inquiries unconnected with reasons recorded in reassessment proceedings not allowed

Conditions to reopen u/s. 147 after 4 years from end of relevant A.Y.
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.
