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

Reopening Assessment Needs 'Reason to Believe,' Not Just 'Suspect,' u/s 147: Improper Due to Opinion Change.

January 15, 2020

Case Laws Income Tax HC

Reopening of assessment u/s 147 - 'reason to believe' or 'reason to suspect' - objections of the petitioner were rejected by a non-speaking and cryptic order - information already available on record - merely because there is a change in opinion, reopening could not have been done

View Source

← Previous Next →

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

Reopening Assessment Needs 'Reason to Believe,' Not Just 'Suspect,' u/s 147: Improper Due to Opinion Change.

January 15, 2020

Case Laws Income Tax HC

You may also like:

Reopening of assessment u/s 147 - reason to believe - commencement date / year for deduction u/s 80IA - Eligible from 1995 or 2000 - scope of change of opinion - We...

Reopening of assessment u/s 147 - ‘reasons to believe’ and ‘reasons to suspect’ - Merely on the basis of suspicion observed that the aforesaid entry might be a bogus...

Reopening of assessment u/s 147 was not valid as the Revenue Audit Report merely pointed out discrepancy in computation method and opined on applicability of Section...

Reopening of assessment u/s 147 - 'reason to believe' OR 'reason to suspect' - AO reopened the assessment based on change of opinion, which is not acceptable as per the...

Reopening of assessment u/s 147 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion...

Reopening of assessment u/s 147 - Reasons to believe or suspect - huge share transaction - The court held that the reasons provided by the Assessing Officer for...

Reopening of assessment u/s 147 - reasons to suspect OR reasons to believe - Power u/s 147 cannot be exercised merely on reason of suspicion but there should be reason to believe.

Reopening of assessment u/s 147 - Reason to believe - change of opinion - The reason we say that there is a change of opinion is because once a query has been raised...

Reopening of assessment u/s 147 - Reasons to believe - AO was not having any reason to believe for initiating re-assessment - There cannot be any re-assessment for a...

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...

Reopening of assessment u/s 147 - Reopening based on audit objections - reasons to believe - High Court observed that, reopening an assessment beyond four years requires...

Reopening of assessment u/s 147 - Eligibility of reason to believe - “Reason to believe” or ‘Reasons to suspect” - According to us, when the AO receives information of...

Reopening of assessment u/s 147 - Validity of reasons to believe - No linkage of the assessee has been established with the information received from investigation wing...

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...

Revision u/s 263 by CIT - reopening of assessment u/s 147 - "reason to suspect" v/s 'reason to believe' - Information adverse may trigger "reason to suspect" and not...

Quick Updates: