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1. Formation of belief by the Assessing Officer that income has escaped assessment is the crux of the reopening provision. The reasons recorded must be based on tangible...

2. The action of reopening of assessment can be resorted to by the AO only if he has tangible material at his command to form a reasonable belief that income chargeable to...

3. Reopening of assessment u/s 147 - As examined the belief of the Assessing Officer to a limited extent to look into whether there was sufficient or any tangible materials...

4. 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...

5. Reopening of assessment u/s 147 justified due to tangible material available with Assessing Officer (AO) to form reasonable belief regarding escapement of income....

6. 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...

7. Reopening of assessment u/s 147 - reason to suspect v/s reason to believe - The reasons disclosed and placed on record do not allude to the material that was available...

8. Reopening of assessment u/s 147 - the notice u/s 148 on the basis of “on verification of records” - the AO has power to reopen the assessment, provided there is...

9. Reopening of assessment u/s 147 was based on reasons to believe the difference between total cash sales and cash sales reflected in books. Held: Reopening was made only...

10. Reopening of assessment u/s 147 - Reasons to believe - It is not the case of the revenue that, subsequently i.e. after the order of scrutiny assessment, the assessing...

11. The High Court held that the reassessment proceedings initiated u/s 148 were invalid. The assessee, a partner in a firm, had disclosed all financial transactions and...

12. 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:...

13. The Assessing Officer (AO) reopened the assessment solely based on the information from a survey conducted by the Sales Tax Department, without independently examining...

14. 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...

15. Reopening of assessment u/s.147 - there is absolutely no tangible material available with the ld. AO having live link to form a belief that income of the assessee had...