Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights July 2019 Year 2019 This

Reassessment u/s 147 - failure on the part of the petitioner to ...


Reassessment u/s 147 invalid as reopening based on AO's change of opinion on Section 80IB(10) claim.

July 16, 2019

Case Laws     Income Tax     HC

Reassessment u/s 147 - failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment - AO had examined the claim for deduction u/s 80IB(10) in detail, therefore, merely because he did not examine such claim from the angle of clauses (e) and (f) thereof, would not be a valid ground for reopening the assessment - it is mere change of opinion - notice unsustainable

View Source

 


 

You may also like:

  1. Reopening of assessment u/s 147 was invalid as Assessing Officer (AO) failed to record that assessee did not disclose fully and truly all material facts necessary for...

  2. 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...

  3. The ITAT Nagpur considered the validity of reassessment proceedings u/s 147. The AO issued notice beyond four years alleging capital gain on "Sale of Vehicles" escaped...

  4. 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...

  5. Reopening of assessment under s.147 challenged on grounds of invalid notice under s.143(2) and "change of opinion." ITAT held notice under s.143(2) was valid as return...

  6. 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...

  7. ITAT dismissed Revenue's appeal against CIT(A)'s order invalidating reassessment proceedings under s.147. AO had previously examined share premium issue during original...

  8. HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to...

  9. Validity of reassessment proceedings u/s 147, the requirement of fresh tangible material for reopening assessment, and the disallowance of expenditure incurred on DAP,...

  10. 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...

  11. Reopening of assessment u/s 147 - Initiation of reassessment proceedings, u/s.148 of the Act and issued notice to the assessee was based on valid reason on the strength...

  12. The HC held that the AO lacked jurisdiction to reopen the assessment beyond four years u/s 147. The reasons did not establish the assessee's failure to fully disclose...

  13. Reopening of assessment u/s 147 - The High Court dismissed the appeal filed by the revenue, affirming the decision of the Income Tax Appellate Tribunal (ITAT) that...

  14. Reopening of assessment u/s 147 or assessment u/s 153C - reassessment was made based on the materials found in the course of search conducted on third party - The...

  15. The crux of the matter revolves around the validity of reassessment proceedings initiated by the Assessing Officer (AO). The critical issue is whether there existed any...

 

Quick Updates:Latest Updates