Home Highlights April 2019 Year 2019 This

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1. Assessment u/s 153C - satisfaction on the basis of the borrowed information - It is true that the supreme Court has made the said observations while considering the...

2. Reopening of assessment u/s 147 - second re-assessment notice u/s 148A - The High Court noted that the petitioner did not challenge the earlier re-assessment order dated...

3. Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT (Inv.) - The repetition of certain portions of the investigation...

4. Reopening of assessment u/s 147 - Reason to believe - The objective satisfaction would be sufficient for the purpose of allowing the Assessing authority to proceed with...

5. Reopening of assessment u/s 147 - As reopening of the assessment has been made on the basis of AIR information which is not based on correct facts and the AO has not...

6. 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...

7. Reopening of assessment u/s 147 v/s assessment u/s 153C - proceedings initiated u/s 132 - The correct course of reassessment is under section 153C not under section 147...

8. Reopening of assessment u/s 147 - This being the scope of Section 147 for reopening of assessment, this Court do not find any acceptable reason for the purpose of...

9. Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the...

10. Reopening of assessment u/s 147 - AO has acted only on the basis of information received from Investigation Wing without any exercise it has own level and only on the...

11. Reopening of assessment u/s 147 - It is sufficient if any one of the conditions stipulated in Proviso clause to Section 147 is satisfied for reopening of assessment. -...

12. Reopening of assessment u/s 147 or 153C - assessment proceedings were initiated mainly on the information found during the search proceedings - jurisdiction lies to...

13. Validity of Assessment u/s 153C - whether AO of the searched person has not recorded satisfaction note that the books of accounts/material belongs to the assessee ? - In...

14. Validity of reopening of assessment u/s 147 - beyond 4 years but within 6 years - Report of the investigation wing might constitute tangible material. The decision to...

15. Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit...