Topic

Section 147 Interpretation

1 articleLatest July 2026
'And' in Sec 147 IT Act is conjunctive, limiting AO jurisdiction to initially escaped income only | ITAT Jaipur
Case Law Analysis
|Income Tax Appellate Tribunal

'And' in Sec 147 IT Act is conjunctive, limiting AO jurisdiction to initially escaped income only | ITAT Jaipur

The Jaipur ITAT ruled that the word ‘and’ in Section 147 operates conjunctively, so an Assessing Officer can only reopen assessment for income already identified as escaped, not for any other income. This narrows reassessment powers and shields taxpayers from unexpected additions. The ruling applies to all cases invoking Section 147 nationwide.