#Section 147
Log in to FollowLatest Section 147 updates, provisions, case laws, compliance requirements, tax implications and expert analysis under Income-tax law on TaxGuru.

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

Whether assessment can be re-opened beyond four years when all primary facts for making the claim were disclosed to the AO

Mere opinion of the Audit Party cannot form the basis for the Assessing Officer to reopen the closed assessment

Full and true disclosures must mean what the statute says and requires specific disclosure of each fact – Bombay HC

Reopening under section 147 For Lapse Of AO Invalid – Delhi High Court

Power to reopen an assessment cannot be exercised to reopen what formed subject matter of an appeal to Commissioner (Appeals)

AO cannot assess other ‘escaped income’ if reason for issue of Notice under section 148 dropped
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.
