Reopening of assessment - Deemed dividend - the reopening of ...

Case Laws Income Tax

October 8, 2018

Reopening of assessment - Deemed dividend - the reopening of assessment was not a case of change of opinion, but it was a case where the assessee did not disclose fully and truly the material facts necessary for the assessment

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Reopening of assessment - Deemed dividend - the reopening of ...

Case Laws Income Tax

October 8, 2018

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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...

Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based...

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...

Validity of reopening an assessment u/s 147 of the Income Tax Act, the distinction between "change of opinion" and "reasons to believe," and the classification of income...

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...

Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not...

Reopening of assessment u/s 147 - reply to the audit objections - in fact AO applied his mind to the audit party objection and formed a clear opinion that there is no...

Reopening of assessment u/s 147 - deemed dividend addition u/s 2(22)(e) - gap of more than four years - when the amount received by the two concerns from the loan giver...

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...

Reopening of assessment u/s 147 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the...

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...

Reopening of the assessment u/s 147 - Reason to believe - change of opinion - merely because another director of the same company had disclosed the income received...

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...

Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for...

Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the...

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