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Income Tax - Highlights / Catch Notes

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Reassessment proceeding under Section 147 was made to form ...


Section 147 Reassessment: Cannot Alter Original Assessment Based on Opinion Change or Review Attempt.

August 29, 2020

Case Laws     Income Tax     HC

Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147 under the pretext of reassessment. We make it clear that in the reassessment proceedings u/s 147, the original assessment order cannot be reviewed. Proceedings also cannot be initiated merely because there is a possibility of change of opinion. - HC

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