Reopening of assessment u/s 147 - Reasons which were supplied to ...

Reassessment u/s 147 Invalidated Due to Mismatched Reasons; Notice u/s 148 Quashed.

June 25, 2020

Case Laws Income Tax AT

Reopening of assessment u/s 147 - Reasons which were supplied to the petitioner were not the actual reasons and the objections which were taken by the petitioner were not to the actual reasons - The entire process would be a sham and would amount to making a mockery of the law. Therefore, for this reason also, the notice under section 148 as well as all proceedings subsequent thereto as also the order are liable to be quashed.

View Source

← Previous Next →

Reopening of assessment u/s 147 - Reasons which were supplied to ...

Reassessment u/s 147 Invalidated Due to Mismatched Reasons; Notice u/s 148 Quashed.

June 25, 2020

Case Laws Income Tax AT

You may also like:

Reassessment u/s 147 - validity of notice - reasons for reopening the assessment have been recorded by the jurisdictional AO viz. the Dy. CIT, Circle 2, Jamnagar but the...

Reassessment u/s. 147 - non availability of file containing reasons to believe - there is no material brought to our notice that reasons were recorded before issue of...

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...

Section 147/148 proceedings can only be initiated based on the original reasons recorded for forming the opinion of escapement of income. The Assessing Officer cannot...

Reopening of assessment u/s 147 - It is well established that the reasons recorded by the AO cannot be further be substituted or added or deleted - We are of the view...

Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint...

Reassessment u/s 147/148 - Initiation of rectification u/s 154 by the AO and simultaneously initiating the reassessment u/s 147/148 on the same reasons, particularly...

Reopening of assessment u/s 147 - unexplained cash payment - Two notices issued u/s 148 - it is a case where pending conclusion of the first reassessment proceedings,...

Validity of assessment made u/s 147 instead of u/s. 153C - Addition as unexplained cash credit u/s. 68 - Upon examination, the ITAT Delhi found that the seized material,...

Validity of the assessment order passed u/s 147 r.w.s. 143(3) - post search assessment - in the case on hand the pending reassessment proceedings u/s 147 got abated by...

Validity of reassessment proceedings - Reason to believe - The tribunal found that there was sufficient "reason to believe" that income had escaped assessment due to the...

Validity of reassessment proceedings challenged - capital gain on co-owned land sale - reassessment based on DVO report alleging suppression of lower valuation - reasons...

Reassessment u/s 147 - notices u/s 133(6), 147/148, 142(1)/143(2) and Assessment Order were never validly served on the assessee due to change in address - assessment...

Reassessment u/s 147 - original assessment u/s 143(3) - notice u/s 148 after expiry of four years - A bare perusal of the recorded reasons shows that there is no whisper...

HC quashed reassessment proceedings under s.147 initiated after four years. AO's reasons revealed information was derived from original assessment documents, indicating...

Quick Updates: