Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights November 2013 Year 2013 This

Re-opening of assessment u/s 147 of the Income Tax Act – Having ...


Section 147 reassessment can't be used to revisit Section 10A deduction if initially ignored by the Assessing Officer.

November 9, 2013

Case Laws     Income Tax     AT

Re-opening of assessment u/s 147 of the Income Tax Act – Having failed to look into a different dimension on which the deduction u/s. 10A could be disallowed to the assessee, the AO cannot be permitted to take recourse to reassessment proceedings u/s. 147 of the Act - AT

View Source

 


 

You may also like:

  1. Section 147 allows reopening of assessments in exceptional cases where the Assessing Officer has reason to believe income has escaped assessment. Concluded assessments...

  2. Reopening of assessment u/s 147 v/s assessment u/s 153C - proceedings initiated u/s 132 - The correct course of reassessment is under section 153C not under section 147...

  3. Reopening of assessment u/s 147 or assessment u/s 153C - reassessment was made based on the materials found in the course of search conducted on third party - The...

  4. Interplay between Sections 153C and 147 of the Income Tax Act, specifically whether recourse to Section 147 is available when the Assessing Officer (AO) is empowered to...

  5. Reopening of assessment u/s 147 - Undisclosed purchase of land - the fact was discovered by the Assessing Officer on the basis of the report of District Registrar - the...

  6. Section 147/148 proceedings can only be initiated based on the original reasons recorded for forming the opinion of escapement of income. The Assessing Officer cannot...

  7. Reopening of assessment u/s 147 - Disallowance u/s 14A - If at all he has considered, he has not even passed the assessment order by ignoring the provisions of law, i.e....

  8. The HC upheld the Appellate Tribunal's decision that reassessment under Section 147 was invalid. Although Explanation 1 to Section 147 states that mere production of...

  9. The High Court held that the jurisdictional facts necessary to invoke Section 147 for reassessment were absent. The reassessment was initiated after the four-year...

  10. Assessment u/s 147 versus 153C - choice of correct course of assessment. The assessee's name featured in the list of beneficiaries of accommodation entries by way of...

  11. Reopening of assessment u/s 147 - Deduction u/s 80-IA - Without any application of mind, the Assessing Officer re-opened the assessment under the pretext that income has...

  12. Validity of reopening an assessment beyond four years from the end of the relevant assessment year, denial of deduction u/s 54F, and the addition on the ground of owning...

  13. Validity of the assessment order passed u/s 147 r.w.s. 143(3) - post search assessment - in the case on hand the pending reassessment proceedings u/s 147 got abated by...

  14. Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147...

  15. Reopening of assessment u/s 147 - It is well established that the reasons recorded by the AO cannot be further be substituted or added or deleted - We are of the view...

 

Quick Updates:Latest Updates