Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights July 2020 Year 2020 This

Validity of Reopening of assessment - change of opinion - If the ...

Case Laws     Income Tax

July 17, 2020

Validity of Reopening of assessment - change of opinion - If the very same reasons were the subject matter of the proceedings under Section 143(3) of the Act or the proceedings under Section 263 of the Act, once again, for the very same reasons, the power under Section 147 cannot be invoked and having done so, the CIT(A) as well as the Tribunal were right in coming to the conclusion that the reopening was bad in law.

View Source

 


 

You may also like:

  1. 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...

  2. 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...

  3. 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...

  4. 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...

  5. Reopening of assessment - notice issued after the expiry of more than 4 years - Capitalization of interest income - The High Court observed that, the AO having raised a...

  6. Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for...

  7. Validity of Reopening of assessment u/s 147 - Existence of reason to believe - The issue squarely falls in the realm “change of opinion”. In our view, the only reason...

  8. Validity of reopening of assessment - It is well settled Law that validity of the reassessment proceedings is to be judged with reference to the reasons recorded for...

  9. Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based...

  10. 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...

  11. Reopening of assessment u/s 147 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the...

  12. The assessment order was challenged on the grounds of validity of reopening after four years, based on a change of opinion and borrowed satisfaction. The assessee...

  13. Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but...

  14. Validity of reopening of assessment u/s 147 - Proof of new material to justify the re-opening of the assessment - change of opinion - there was conscious application of...

  15. Validity of reopening an assessment u/s 147 of the Income Tax Act, the distinction between "change of opinion" and "reasons to believe," and the classification of income...

 

Quick Updates:Latest Updates