The Direct tax Committee of PHDCCI recently organised a Seminar on Reassessment under section 147-148 of Income Tax Act, 1961 (Physical & Virtual) at PHD House, New Delhi.
The Chief Guest Mr. G S Pannu, Former President, INCOME TAX APPELLATE TRIBUNAL (ITAT) apprised that Reassessment must be used sparingly — backed by fresh material, clear reasoning, and strict adherence to procedure. It is not a tool to routinely revisit completed assessments. The integrity of the process matters just as much as the outcome. He complimented and appreciated PHDCCI to conceptualize and organize such a wonderful seminar on extremely important subject.
In his welcome address Mr. Mukul Bagla, Chair, Direct Taxes Committee said the entire method of Section 148 has changed in the income tax bill. Reassessment time limit of upto 10 years has shortened to 5 years, which was a very welcome change. Sections 147 and 148 empower tax authorities to reopen cases, but this power must be exercised with caution. Only fresh, tangible material—not mere suspicion—can justify reopening. Procedural integrity and judicial discipline are essential to uphold fairness.
Dr. Rakesh Gupta, Co-Chair, Direct Taxes Committee emphasised that the Reassessment is not a routine exercise — it must be founded on new, tangible information and a clear application of mind. Sections 147–148 require strict adherence to procedure, fairness to the assessee, and a rational link between the material and belief. Courts have made it clear: due process is not optional.
Mr Suyash Raj Nahata, Co-Chair, Direct Tax Committee said that Reassessment regime under Sections 147 and 148 has undergone a major overhaul. Today, it’s not just about substance — it’s equally about procedure. Notices, timelines, approvals, reasons — every link must align with legal requirements. If one link breaks, the whole chain collapses. Reassessment is not just a departmental tool, it is a legal process that must be respected
Mr. Rohit Jain, Partner, Vaish Associates addressed the complexities around Section 147. He highlighted repeated changes in reassessment regimes, mentioned that its like short-lived marriage with search assessments and controversies that have emerged over the last 4 years. Further deliberated on sanctioning authority, surviving period, etc.
Mr. Gagan Kumar, Advocate, Krishnomics Legal said that the Reassessment under the Income Tax Act has long been a contentious subject. With frequent legislative amendments, the complexities surrounding it have only deepened. Adding to the challenge are the divergent judgments delivered by various High Courts, often reflecting conflicting interpretations of the law. In this context, the seminar organised by PHD Chamber was both timely and significant.
The session was attended by about 240 Participants, both physically (170) and virtually (70).
