Reopening of assessment u/s 147 - validity of reason to believe ...

Reopening Tax Assessment Invalid if AO Relies Solely on DDIT Report, Lacks Independent Reasoning (Section 147.

November 19, 2019

Case Laws Income Tax AT

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 report of DDIT without any reasons independently recorded by the AO on the basis of ‘borrowed satisfaction’ of the DDIT (Inv.) cannot be the basis for reopening of assessment u/s. 147 of the Act.

View Source

← Previous Next →

Reopening of assessment u/s 147 - validity of reason to believe ...

Reopening Tax Assessment Invalid if AO Relies Solely on DDIT Report, Lacks Independent Reasoning (Section 147.

November 19, 2019

Case Laws Income Tax AT

You may also like:

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

Reopening of assessment based on credible information from Investigation Wing was invalid. Addition u/s 68 regarding unaccounted money ploughed back as share capital and...

The HC held that the Assessing Officer could not reopen the assessment for AY 2013-14 merely relying on information from the insight portal without forming an...

The assessment years beyond six years but not exceeding ten years can be reopened u/s 153A only if the Assessing Officer possesses evidence depicting escapement of...

Reopening of assessment u/s 147 - non independent application of mind by AO - Scope of borrowed satisfaction - The Appellate Tribunal found that the reopening was solely...

The Appellate Tribunal (ITAT) considered the validity of reopening an assessment where the assessee's objections were not addressed. The power to reopen assessment lies...

The HC quashed the reopening of assessment u/s 147, holding that the AO did not apply independent mind and relied solely on borrowed satisfaction from information on the...

The High Court revisited the reopening of assessment u/s 147 due to the assessee's involvement in penny share transactions. The petitioner invested in shares through IPO...

Validity of reopening assessment u/s 147 - the reopening of assessment made by the AO on irrelevant facts and on a mere reason to suspect cannot survive. We hold that...

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...

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 u/s 147 - Non dealing with objections - In the present case, apart from the fact that the reopening of the assessment being bad in law for...

Reopening of assessment u/s 147 - Unexplained loan - There were no justification for the A.O. to record non-existing, incorrect and wrong facts in the reasons for...

Reopening of assessment u/s 147 - Tribunal was correct to hold that when reference was made to the TPO by AO for determination of arm’s length price in relation to the...

ITAT ruled the assessment order invalid due to procedural deficiencies and lack of proper jurisdiction. The AO failed to issue mandatory notice under Section 143(2)...

Quick Updates: