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of <h1>Guidance on Reopening Assessments u/s 147: Ensure Legal Compliance to Avoid Invalid Notices and Revenue Loss.</h1> The circular addresses the reopening of assessments under Section 147 of the Income Tax Act, 1961, emphasizing the need for compliance with legal requirements. Despite prior instructions, proposals for reopening assessments often lack legal adequacy, leading to quashed proceedings and revenue loss. It highlights two Supreme Court cases: Chugamal Rajpal vs. S.P. Chaliah, where a notice under Section 148 was deemed invalid due to insufficient reasoning, and Sheonath Singh vs. A.A.C., where reasons for belief were inadequate. The circular stresses that reasons must be based on reasonable grounds, not mere suspicion, and urges officers to adhere to these judicial observations.
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