Information under section 147(b) - audit opinions do not qualify; only communicated law or new facts justify reopening assessments. The meaning of information for section 147(b) is limited to factual particulars or knowledge of law originating from a formal source; audit opinions on interpretation do not constitute such information. An ITO must independently evaluate any law or facts communicated by audit notes and record those specific facts or law as the basis for a reason to believe that income has escaped assessment. Rectification, supervisory review, or other remedial routes should be considered where reopening is not justified, and action must respect statutory time limits and supervisory approvals.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Information under section 147(b) - audit opinions do not qualify; only communicated law or new facts justify reopening assessments.
The meaning of information for section 147(b) is limited to factual particulars or knowledge of law originating from a formal source; audit opinions on interpretation do not constitute such information. An ITO must independently evaluate any law or facts communicated by audit notes and record those specific facts or law as the basis for a reason to believe that income has escaped assessment. Rectification, supervisory review, or other remedial routes should be considered where reopening is not justified, and action must respect statutory time limits and supervisory approvals.
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