Section 147 → Section 165
Income escaping assessment (Reassessment)
Quick Answer
Section 147 of the Income Tax Act, 1961 (Income escaping assessment (Reassessment)) corresponds to Section 165 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.
What changed for Section 147
Section 147 of the 1961 Act sets out the rules on income escaping assessment (reassessment). Power to reopen past assessments if the AO has reason to believe income has escaped tax.
Under the Income-tax Act, 2025 (effective 1st April 2026), Section 147 is retained and renumbered as Section 165 of the Income-tax Act, 2025. Retained. Reopening is now 'Information-driven' based on the Risk Management Strategy of the CBDT.
The transition impact on Section 147 is assessed as Critical. The most litigated area of income tax.
Sec 147
Provision Summary
Power to reopen past assessments if the AO has reason to believe income has escaped tax.
Sec 165
Provision Summary
Retained. Reopening is now 'Information-driven' based on the Risk Management Strategy of the CBDT.
Key Changes & Highlights
- The concept of 'Reason to Believe' is replaced by 'Information suggesting escapement'.
Related Sections
Frequently Asked Questions
Which subject does Section 147 of the 1961 Act cover?
Section 147 of the Income Tax Act, 1961 covers income escaping assessment (reassessment). Power to reopen past assessments if the AO has reason to believe income has escaped tax.
What is the new section number for Section 147 under the Income-tax Act, 2025?
Section 147 of the Income Tax Act, 1961 maps to Section 165 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Reopening is now 'Information-driven' based on the Risk Management Strategy of the CBDT.
How does the Income-tax Act, 2025 affect Section 147 in practice?
The transition impact for Section 147 is rated Critical. The most litigated area of income tax.
What is new about Section 147 under the Income-tax Act, 2025?
The concept of 'Reason to Believe' is replaced by 'Information suggesting escapement'. These points are specific to Section 147 (Income escaping assessment (Reassessment)).
Disclaimer: This mapping of Section 147 (Income escaping assessment (Reassessment)) to Section 165 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 147 is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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