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Income Tax - Highlights / Catch Notes

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Reassessment u/s 147 - Performance Linked Incentive disallowed – ...

Case Laws     Income Tax

November 18, 2014

Reassessment u/s 147 - Performance Linked Incentive disallowed – it was a case of change of opinion and the AO has not brought on record any fresh material or information for assuming jurisdiction u/s 147 of the Act - AT

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  1. 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...

  2. The ITAT Nagpur considered the validity of reassessment proceedings u/s 147. The AO issued notice beyond four years alleging capital gain on "Sale of Vehicles" escaped...

  3. Reopening of assessment u/s 147 - Reasons to belive - change of opinion - there was no new material which had come to the notice of the Assessing Officer and the entire...

  4. Reassessment order u/s 147 - the AO does not enjoy the power of review. Therefore in the present case it is clear that the action of the present AO tantamount to review...

  5. Reopening of assessment u/s 147 - Change of opinion - the threshold bar for initiation of the reassessment proceedings is satisfied. This Court must conclude, at this...

  6. Reopening of assessment u/s 147 - reason to believe - commencement date / year for deduction u/s 80IA - Eligible from 1995 or 2000 - scope of change of opinion - We...

  7. The Calcutta High Court examined the validity of reassessment proceedings u/s 147 based on change of opinion regarding the assessee's liability u/s 115JB. The Court...

  8. Reopening of assessment u/s 147 - validity of reasons to believe - the reassessment proceeding under section 147 has not been validly initiated because the same has been...

  9. The High Court held that the Assessing Officer cannot reopen the assessment u/s 147 merely based on a change of opinion. The assessee had fully and truly disclosed all...

  10. The Delhi High Court examined the validity of reassessment proceedings u/s 147 after a four-year lapse. The court emphasized the requirement of "reasons to believe" for...

  11. Reopening of assessment u/s 147 - change of opinion - The Assessing Officer simply has accorded a fresh consideration and come to a conclusion that the assessee ought to...

  12. Reopening of assessment u/s 147 - The High Court dismissed the appeal filed by the revenue, affirming the decision of the Income Tax Appellate Tribunal (ITAT) that...

  13. The case involves the validity of reopening of assessment u/s 147/148 based on reasons to believe, where the head of income was changed from business to income from...

  14. Issue of reassessment u/s 263, where the Commissioner of Income Tax (CIT) upheld the reassessment as erroneous and prejudicial to the Revenue's interest for verification...

  15. Reopening of assessment u/s 147 - reasons were recorded on receipt of information from Investigation Wing - Apart from this information, which has been taken as gospel...

 

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