Reopening of assessment u/s 147 - unpaid loan liability - AO has ...

Challenge to Reopening Assessment: Lack of Rationale by AO on Unpaid Loan Liability u/s 147 Questioned.

January 29, 2020

Case Laws Income Tax HC

Reopening of assessment u/s 147 - unpaid loan liability - AO has not shown any rational for involving Section 56 to the transaction of loan. The reasons are completely and wholly silent as to how the provisions of Section 56 are attracted in respect of outstanding liability of loan. Moreover, the reasons also do not spell out as to how there has been escapement of income by the assessee.

View Source

← Previous Next →

Reopening of assessment u/s 147 - unpaid loan liability - AO has ...

Challenge to Reopening Assessment: Lack of Rationale by AO on Unpaid Loan Liability u/s 147 Questioned.

January 29, 2020

Case Laws Income Tax HC

You may also like:

Section 147 allows reopening of assessments in exceptional cases where the Assessing Officer has reason to believe income has escaped assessment. Concluded assessments...

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...

Validity of reopening of assessment u/s 147 - AO has not even made minimum exercise for ascertaining the unsecured loans accepted during the year, under consideration...

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...

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...

Reopening of assessment u/s 147 - reply to the audit objections - in fact AO applied his mind to the audit party objection and formed a clear opinion that there is no...

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...

Reopening of assessment u/s 147 - Addition u/s 68 - unexplained share premium - While recording the reasons for reopening the assessment, the AO did not even care to...

The High Court held that the Assessing Officer (AO) had specifically called for and considered information regarding unsecured loans during the original assessment...

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 - No addition being loan given forming the main `reason for escapement of income’ u/s 147 of the Act has been made by the AO and instead,...

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 u/s 147 - Non–disposal of objections challenging the validity of re–opening of assessment u/s 147 is not a mere procedural lapse but effects the...

Validity of Reopening of assessment u/s 147 - When the primary facts necessary for assessment are fully and truly disclosed, the AO is not entitled on change of opinion...

Reopening of assessment u/s 147 - net loss of cancellation of forward contract - When the primary facts necessary for assessment are fully and truly disclosed, the AO is...

Quick Updates: