INCOME ESCAPING ASSESSMENT U/S 147

For this purpose you have to first understand the concept of Merger:

Concept of merger tells that order of Lower authority got merged with order of Higher Authority.

Now This Concept of Merger is further Bifurcated in two parts: PARTIAL MERGER and TOTAL MERGER.

CONCEPT OF PARTIAL MERGER:

If any CASE is pending with Higher Authority [say CIT(A)] then lower authority (i.e AO) can't open that MATTER which are pending in such appeal.

CONCEPT OF TOTAL MERGER:

If any CASE is pending with Higher Authority [say CIT] then lower authority (i.e AO) can't open ANY MATTER which are pending in such appeal.

In the entire act Concept of Partial Merger has been affirmed EXCEPT under section 264.

Now coming to your query-
Under Section 147 concept of PARTIAL MERGER has been affirmed which means THAT MATTER WHICH HAVE BEEN GONE FOR APPEAL CAN'T BE OPENED U/S 147. But the matter which which has not been disputed can be opened and Disallowed later on by AO.

thank you so much

You are most welcome.

Wow. Nitesh sir you are always amazing. Believe me my concept has been clear by this Explaination.

Thanks you very much. Also could you help me with GST RCM concept? A bit Explaination about that would really be appreciated. Thanks sir.

Thank you so much Vishesh. I love to be helpful to others. I would definitely Explain you about RCM thoroughly.

I have already received many questions on this when GST was just introduced and still getting. So I have recemtly written a Blog on this Topic you could go through that. In case of any trouble just put me a message over PM or open a new thread. I will definitely reply in details. Here is the Link:

https://taxeffects.blogspot.com/2018/11/reverse-charge-mechanism-rcm-under-gst.H T M L?m=1


Thank you so much. N Be helpful to One Another!

@ Nitesh Sir this link is not working. What to do?

https://taxeffects.blogspot.com/2018/11/reverse-charge-mechanism-rcm-under-gst.H T M L

Sir same problem. Not showing anything.

I think there is some technical problem. You just simply go to

taxeffects.blogspot.com

and open the first blog that is the RCM. In case of any problem do PM me.

Please Do not Message here! It might be disturbing for others. Hope you understand. Thanks.

I have seen this blog Nitesh ji. You have put everything so well. Thank you so much :-)