#Section 147
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Reassessment on the basis of Income Tax amendment not justified

HC Reverses Law on Supply of Reasons for Reopening – Need not be supplied within limitation period

S.147 Change of opinion if AO not specifically apply his mind? Referred to Full Bench

s.148 notice beyond 4 years without compliance of s.147 & s.151(2) not valid

Validity of notice u/s 148 for re-opening of assessment when jurisdiction was founded merely on the possibility of escapement

S.148 notice after 4 years not valid if Assessee disclosed full & true particular of claim at the time of original assessment proceeding

Extension of time for completion of assessments and reassessments

Budget 2012 – Reopening time limit Increased to 16 Years for income in relation to asset located outside India

Reopening Notice u/s 147 issued within Limitation Period but served after Limitation Period is valid

Section 147 applies both to section 143(1) as well as section 143(3) – No reopening u/s 147 in absence of ‘new material’

For exercise of power U/s. 263, it is mandatory that order passed by AO should be erroneous and prejudicial to interest of Revenue

Delay in notice U/s. 143(2) Renders Assessment Void – HC

Retrospective amendment no basis to reopen beyond 4 years – HC Disapproves AO’s Practice to Delay Passing Objection Orders

Sanction of CIT instead of JCIT renders reopening u/s. 147 of Income Tax Act invalid
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.
