Reopening of assessment u/s 147 - reasons for re-opening the ...

Case Laws Income Tax

March 26, 2020

Reopening of assessment u/s 147 - reasons for re-opening the assessment - change of opinion or not - mere filing to the annexure by the petitioner in response to notice during scrutiny assessment by itself may or may not have been sufficient to come to the conclusion that there was full and true disclosure by the petitioner if the information furnished was neither complete nor true.

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Reopening of assessment u/s 147 - reasons for re-opening the ...

Case Laws Income Tax

March 26, 2020

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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...

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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 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not...

Reopening of assessment u/s 147 - double deduction u/s 80IB - In the reasons for re-opening, there is not even a whisper as to what was not disclosed. In our view, this...

Reopening of assessment u/s 147 was challenged on the ground of mere change of opinion. The assessee had filed return claiming deduction u/s 80IC and furnished all...

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 - change of opinion - The reason we say that there is a change of opinion is because once a query has been raised...

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...

Reopening of assessment u/s 147 - reason to believe - Assessing Officer has no power to review; he has the power to re-assess. But re-assessment has to be based on...

Reopening of assessment u/s 147 - sufficiency or inadequacy of reasons - There is no whisper in the impugned order as regards any failure on the part of petitioner to...

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 - change of opinion - when the primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not...

Reopening of assessment u/s 147 - change of opinion - The impugned notice and the consequent action is legally unsustainable as the Revenue fails to satisfy the twin...

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...

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