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Income Tax - Highlights / Catch Notes

Home Highlights March 2019 Year 2019 This

Reopening of assessment u/s 147 - original assessment u/s 143(3) ...

Case Laws     Income Tax

March 19, 2019

Reopening of assessment u/s 147 - original assessment u/s 143(3) - change of opinion - allegation of non-disclosure not find favour from court - Once there is finding that reasons to believe are not good reasons, jurisdiction is not derived to compel assessee to submit to reassessment.

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  1. 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...

  2. Reopening of assessment u/s 147 - assessment after 4 years - reason to suspect OR reason to believe - Reopening of assessment which is already concluded under Section...

  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. Validity of reopening of assessment u/s 147 - In the instant case the primary facts were already disclosed in the Notes to Accounts filed along with the balance-sheet...

  5. Reopening of assessment u/s 147 - reopening after expiry of four years - Original assessment have been passed under section 143(3) on Dated 14.12.2011 and A.O. recorded...

  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. The Appellate Tribunal considered the validity of the reopening of assessment u/s 147 beyond four years. The assessment was based on notes to accounts for AY 2009-10....

  8. Reopening of assessment u/s 147 - it is not permissible to adopt different standards while interpreting the words “reason to believe” vis-a-vis Section 143(1) and...

  9. Reassessment u/s 147 - original order u/s 143(3) - once finding of fact recorded that no new material has surfaced on the basis of which the assessment proceedings could...

  10. Reopening of assessment u/s 147 was challenged. The Assessing Officer (AO) had disallowed 20% of total sundry creditors in the regular assessment u/s 143(3). The AO...

  11. Reopening of assessment u/s 147 - eligible reasons to believe - In the instant case, as stated by the respondent in the affidavit-in- reply, the petitioner had not...

  12. Revision u/s 263 - period of limitation - the case was re-assessed u/s. 143(3) r.w.s. 147 - the case of the assessee was again reopened and the assessment u/s. 143(3)...

  13. 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...

  14. 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...

  15. Revision u/s 263 - Period of limitation - To be commenced from original assessment order or re-assessment order u/s 147 - In the case on hand, the jurisdiction under...

 

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