#Section 147
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It cannot be said that AO has not applied his mind when all material was placed by Assessee before him
![CIT v. Thayaballi Mulla Jeevaji Kapasi [1967] 66 ITR 147 (SC)](https://taxguru.in/wp-content/uploads/2026/07/Categories_SUPREME-Court.jpg)
CIT v. Thayaballi Mulla Jeevaji Kapasi [1967] 66 ITR 147 (SC)
![CIT v. Kurban Hussain Ibrahimji Mithiborwala [1971] 82 ITR 821 (SC)](https://taxguru.in/wp-content/uploads/2026/07/Categories_SUPREME-Court.jpg)
CIT v. Kurban Hussain Ibrahimji Mithiborwala [1971] 82 ITR 821 (SC)

Southern Switchgears Ltd. v. CIT (Supreme Court) 1998 232 ITR 359

A.L.A. Firm v. CIT (Supreme Court) (1991) 189 ITR 285 (SC)

Powers of A.O to re-open assessment under amended Section147

For Reassessment Issue of notice U/s. 148 is mandatory

Assessment under income tax law can not be made on bare suspicion
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.
