Reopening of assessment u/s 147 - the learned Single Judge was ...

Court Rules Jurisdictional Requirements for Section 147/148 Not Met; Notice Deemed 'Change of Opinion' and Dismissed.

April 16, 2021

Case Laws Income Tax HC

Reopening of assessment u/s 147 - the learned Single Judge was justified in coming to the conclusion that the jurisdictional requirements for invocation of Section 147/148 of the Act in the instant case were not satisfied and therefore, the impugned notice was only a case of 'change of opinion' and did not come within the scope and ambit of 'reason to believe'. - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - the learned Single Judge was ...

Court Rules Jurisdictional Requirements for Section 147/148 Not Met; Notice Deemed 'Change of Opinion' and Dismissed.

April 16, 2021

Case Laws Income Tax HC

You may also like:

The High Court held that for a valid reassessment notice u/s 148 of the Income Tax Act, the Revenue must comply with Section 151A, which mandates the issuance of such...

The court held that the notices issued u/s 133(6) and the subsequent notice u/s 148 of the Income Tax Act were invalid. The petitioner had filed a reply to the notice...

ITAT invalidated reassessment proceedings due to jurisdictional defects in notice issuance under s.148. ITO Ward 3(2), Bulandsahar transferred assessee's records to ITO...

The Madras High Court considered the issue of personal hearing notice u/s FEMA 1999. The Court held that Rule 4(3) does not require the reasoned opinion to be...

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

Issue of faceless assessment of income escaping assessment, where the notice u/s 148 of the Income Tax Act was issued by the Jurisdictional Assessing Officer (JAO)...

Petitioner availed alternate remedy of filing substantive appeal against assessment order and notices issued u/ss 148A and 148 of the Act. Court held that if assessment...

Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of...

The High Court ruled that the Joint Assistant Commissioner (JAO) lacked jurisdiction to issue notices u/s 148 for reassessment of income escaping assessment. The notices...

The Appellate Tribunal considered the validity of a re-assessment notice issued by the jurisdictional AO instead of the designated Faceless Assessing Officer (FAO) as...

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...

The High Court held that the notice issued by the Jurisdictional Assessing Officer (JAO) u/s 148 was invalid as the provisions of Section 151A mandate that such notice...

Reopening of assessment u/s 147 - notice under section 148 has been issued by a non jurisdictional AO - It is settled principle of law that when the notice under section...

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...

Faceless assessment scheme - jurisdictional issue regarding Jurisdictional Assessing Officer (JAO) issuing notice u/s 148 for reassessment. Principal authority's power...

Quick Updates: