Section 147 Reassessment income said to have escaped — well-defended.
Section 147 allows the Assessing Officer to reassess income that has allegedly escaped assessment. Post Finance Act 2021, the procedure runs through Sections 148A, 148, and 149 — with strict timelines, recorded reasons, and a defined inquiry stage that must be defended properly.
Section 147 of the Income Tax Act empowers the AO to assess or reassess income that has escaped assessment in any earlier year. Post Finance Act 2021, the procedure has been significantly tightened — the AO must first issue a notice under Section 148A(b) with information suggesting escapement, give the assessee an opportunity to respond, pass a 148A(d) order, and only then issue a Section 148 notice for reassessment.
Time limits under Section 149 are also stricter. Reassessment can be initiated within three years generally, and within ten years in cases where the income escaping assessment is represented in the form of an asset, expenditure, or entry exceeding fifty lakh rupees — subject to specific conditions and prior approval.
Our 147 defence covers every stage — from responding to the 148A(b) inquiry notice, contesting the reasons recorded, challenging jurisdiction and approvals where appropriate, defending the merits in 147 proceedings, and pursuing appeal before CIT(A) and ITAT where the order is adverse. Jurisdictional and procedural defences are often as important as the merits.
Our 147 Defence Services
148A(b) Inquiry Response
Drafting and filing a reply to the inquiry notice under Section 148A(b) within the prescribed window.
Reasons Recorded Analysis
Detailed analysis of reasons recorded for reopening and identification of jurisdictional defects.
148A(d) Order Challenge
Where the 148A(d) order is patently illegal, advice on writ petition before the High Court.
Section 148 Reply
Filing of return in response to Section 148 notice and contesting the reopening on jurisdiction and merits.
Reassessment Submissions
Written submissions in 147 proceedings on facts, law, and judicial precedents.
Approval & Sanction Defence
Examining whether prior approvals and sanctions under Section 151 are valid and properly obtained.
Faceless 147 Representation
Complete faceless assessment representation including VC hearings and supplementary submissions.
Appeal & Writ Strategy
Strategic advice on appellate remedy before CIT(A) and ITAT or constitutional remedy before the High Court.
Our 147 Defence
Notice Analysis
Study of 148A(b) information, reasons recorded, and the assessment year sought to be reopened.
Inquiry Reply
Drafting and filing the response to the inquiry notice with documentary and legal grounds.
148 Compliance
Filing return in response to Section 148 and contesting jurisdiction and merits in parallel.
Assessment Submissions
Detailed written submissions, evidence, and case-law presented during reassessment proceedings.
Order & Remedy
Review of the reassessment order and advice on appeal, revision, or further writ remedy.
Why Expert Defence Helps
Frequently Asked Questions
Section 147 of the Income Tax Act allows the Assessing Officer to reassess income that has escaped assessment in earlier years, subject to procedural safeguards in Sections 148A, 148, and 149.
Generally three years from the end of the relevant assessment year, extendable to ten years in cases where the alleged escaped income, represented as an asset, expenditure, or entry, exceeds fifty lakh rupees.
Yes, post Finance Act 2021, the AO must conduct an inquiry under Section 148A and pass an order under 148A(d) before issuing a Section 148 reassessment notice, except in specified search and survey cases.
Yes. Jurisdictional defects — invalid reasons, lack of approval, time-barred notice, change of opinion — can be challenged in the reassessment proceeding or by writ petition.
You can file an appeal before CIT(A) within 30 days and pursue further remedies at ITAT and High Court, depending on the issues involved.
Reopened Under Section 147?
Reassessments hinge on jurisdiction, approvals, and reasons recorded as much as on merits. Talk to our team for a structured defence at every stage.
Defend a 147 Reopening or call +91 9819 000 511