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 August 2015 Year 2015 This

Reopening of assessment u/s 147 r.w.s. 148 - since the ...


Reassessment u/ss 147 and 148 Upheld: No "Change of Opinion" as Initial Return Accepted Without Review.

August 13, 2015

Case Laws     Income Tax     SC

Reopening of assessment u/s 147 r.w.s. 148 - since the assessee's return was accepted under section 143(1) of the Income-tax Act, there was no question of "change of opinion" inasmuch as while accepting the return under the aforesaid provision no opinion was formed - reassessment proceedings sustained - SC

View Source

 


 

You may also like:

  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 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...

  3. 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...

  4. Reopening of assessment u/s 147 was challenged on the ground of mere change of opinion. The assessee had filed return claiming deduction u/s 80IC and furnished all...

  5. Reopening of assessment u/s 147 where assessment proceedings already pending - Unless the return of income already filed is disposed of, the notice for reassessment u/s...

  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. Validity of assessment u/s 147 - it is not a return u/s 119(2)(b) albeit it is a return filed in response to notice u/s 148 which has been accepted by the AO. Thus, when...

  8. Reopening of assessment u/s 147 - Initiation of reassessment proceedings, u/s.148 of the Act and issued notice to the assessee was based on valid reason on the strength...

  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. 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...

  11. 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...

  12. 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...

  13. HC determined reassessment proceedings initiated under s.147/148 were invalid when based on materials discovered during search operation under s.132. Where incriminating...

  14. Reassessment u/s 147 - notices u/s 133(6), 147/148, 142(1)/143(2) and Assessment Order were never validly served on the assessee due to change in address - assessment...

  15. 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...

 

Quick Updates:Latest Updates