Reopening of assessment u/s 147 - Pr.CIT has recorded his ...

Section 147 Assessment Reopening Invalid: Pr.CIT's Approval u/s 151 Lacks Proper Consideration, Deemed Mechanical and Ritualistic.

March 23, 2021

Case Laws Income Tax AT

Reopening of assessment u/s 147 - Pr.CIT has recorded his satisfaction for reopening of the assessment in a most mechanical manner without considering even the assessment records or the return of income filed by assessee and his satisfaction appears to be in a ritualistic and formal rather than meaningful. - Therefore, such approval under section 151 of the I.T. Act, 1961, is totally without application of mind and as such the satisfaction cannot be said to be valid in the eyes of Law. - AT

View Source

← Previous Next →

Reopening of assessment u/s 147 - Pr.CIT has recorded his ...

Section 147 Assessment Reopening Invalid: Pr.CIT's Approval u/s 151 Lacks Proper Consideration, Deemed Mechanical and Ritualistic.

March 23, 2021

Case Laws Income Tax AT

You may also like:

Validity of reopening of assessment - no approval was taken U/s 151 - The tribunal found that the notice issued under section 148/143(3) lacked proper approval under...

Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval...

The ITAT Delhi held that the reopening of assessment u/s 147 was invalid as the JCIT granted approval mechanically without proper application of mind. The JCIT's...

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 - 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 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was...

Reopening of assessment u/s 147 - Fresh sanction under Section 151 - For a moment, even if accept Revenue’s contention that the present proceedings are continuation of...

Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following...

Reopening of assessment u/s 147 - Bypassing the option to initiate scrutiny assessment u/s 143(3) - The assessment proceedings would cease to be pending either by...

Reopening of assessment u/s 147 was invalid due to lack of valid sanction as required u/s 151. The competent authority must independently apply its mind based on...

Reopening of assessment u/s 147 - Addition u/s 14A read with Rule 8D. "Reason to believe" in Section 147 means cause or justification for the competent authority to...

Validity of reopening assessment u/s 147 - the reopening of assessment made by the AO on irrelevant facts and on a mere reason to suspect cannot survive. We hold that...

ITAT upheld the validity of reopening assessment under Section 147, rejecting the assessee's challenge to the Section 148 notice. The Tribunal found that since no...

Reopening of assessment u/s 147 was invalid as Assessing Officer (AO) failed to record that assessee did not disclose fully and truly all material facts necessary for...

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...

Quick Updates: