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1. The case pertains to the reopening of assessment u/s 147 of the Income Tax Act. The key points are: The department had already raised queries regarding the accumulation...

2. Reopening of assessment u/s 147 - Period of limitation - The audit party is entitled to point out a factual error or omission in the assessment. reopening of the...

3. The Appellate Tribunal examined the reopening of assessment after four years and the addition u/s 68 of the Income Tax Act. It held that the original assessment was...

4. The assessment order was challenged on the grounds of validity of reopening after four years, based on a change of opinion and borrowed satisfaction. The assessee...

5. Reopening of assessment u/s 147 - Change of opinion - We are of a strong conviction that in the garb of reopening the case of the assessee he had on the basis of the...

6. Reopening of assessment u/s 147 - Mere production of books of account and the details by the assessee are one aspect of the matter and even with reference to such books...

7. Validity of assessment u/s 153A - Non issuance of notice U/s 143(2) - Protective assessment - the assessment has been made on a protective basis, but, it is not clear...

8. Validity of reopening of assessment - It is well settled Law that validity of the reassessment proceedings is to be judged with reference to the reasons recorded for...

9. Reopening of assessment u/s 147 r.w.s. 148 - We reject the argument of AR that even in the case where there is no assessment made by the AO or the return is processed...

10. Reopening of assessment u/s 147 - bogus purchases - AO having not carried out the scrutiny assessment within the prescribed statutory limit, cannot be given another...

11. Reopening of assessment u/s 147 - the very basis of reopening of assessment is based on incomplete or wrong facts available on record as the said transaction of sale of...

12. Validity of reopening of assessment u/s 147 - validity of reason to believe - during the scrutiny assessment, the case was discussed with the assessee on four dates,...

13. The case pertains to the reopening of assessment u/s 147/148 of the Income Tax Act due to undisclosed cash deposits in the assessee's bank accounts. The key points are:...

14. Reopening of assessment u/s 147 - reason to believe - there was tangible material before the AO to reopen the concluded assessment as the assessee is claiming huge...

15. Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a...