#Section 147
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Reopening of assessment under section 147 for mistakes that could be rectified under section 154 is invalid

On non-compliance with statutory condition precedent, reopening of an assessment cannot be sustained

Reopening of an assessment on mere change of opinion without any tangible material is unsustainable

Income Tax – Reasseement can not be done under section 147 for rectification of mistake U/s. 154 – Mumbai HC

Reasons recorded by AO for reopening an assessment are the only reasons which can be considered when formation of belief is impugned

Validity of S.147 reopening has to be determined based on law prevailing on date of issue of S.148 notice

Recourse to the power under Section 147 cannot be sustained on a mere change of opinion

Income cannot be reassessed on a mere change of opinion

Income-Tax Department cannot re-open the assessment U/s. 147 of the Income Tax Act arbitrarily: SC

AO deemed to have applied his mind if facts are on record

Concept of “change of opinion” stands obliterated WEF 01.04.1989?

The assessing authority cannot act on the dictates of the Commissioner to reopen the concluded assessment

Validity of re-opening when no concealment of income and department applied higher tax rate of tax for framing re-assessment

Jurisdiction of AO to proceed with assessment under section 147 of IT Act, 1961
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.
