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 Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
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
What does Section 147 of the Income Tax Act 1961 deal with?
Section 147 (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 Direct Tax Code 2025?
Section 147 of the ITA 1961 maps to Section 165 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 147 under the new tax code?
Section 147 is marked as "Retained" with status "Modified". Impact: Critical - The most litigated area of income tax.
What are the key changes to Section 147 under DTC 2025?
The concept of 'Reason to Believe' is replaced by 'Information suggesting escapement'.
Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.
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