Validity of jurisdiction assumed by AO u/s 147 - Assessment was ...

Assessing Officer's Jurisdiction u/s 147 Invalid Due to Incomplete Assessment and Lack of Valuation Report.

June 11, 2021

Case Laws Income Tax AT

Validity of jurisdiction assumed by AO u/s 147 - Assessment was not complete based not valuation report - While a formal rejection of books may not, at times, be possibly necessary an abstract position of law, an implied dissatisfaction on the books could not be gauged either from the original assessment or from the attendant office note. - CIT(A) has also made reference to various other judgments and has come to the conclusion that ingredients of Section 147 of the Act are not fulfilled in the instant case and consequently reopening is not permissible in the facts and circumstances of the case - AT

View Source

← Previous Next →

Validity of jurisdiction assumed by AO u/s 147 - Assessment was ...

Assessing Officer's Jurisdiction u/s 147 Invalid Due to Incomplete Assessment and Lack of Valuation Report.

June 11, 2021

Case Laws Income Tax AT

You may also like:

Faceless assessment notices issued by Joint Assessing Officer instead of Facessing Assessing Officer held invalid as lacking jurisdiction u/s 151A read with Central...

The High Court quashed the reopening of assessments u/s 148, holding that the reasons recorded by the Assessing Officer were cryptic, vague, lacking nexus, and...

Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessment Officer (FAO) u/s 148A(b) for income escaping assessment is invalid. Faceless...

Reopening of assessment u/s 147 - Assessing Officer to usurp the jurisdiction to reopen the assessment - The first Assessing Officer has made the reassessment after...

Formation of belief by the Assessing Officer that income has escaped assessment is the crux of the reopening provision. The reasons recorded must be based on tangible...

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 notices issued u/s 148 for assessment years 2018-19, 2019-20, and 2020-21 were time-barred by limitation. Withdrawal of approval u/s 10(23C)(vi) by the...

The Appellate Tribunal examined the reopening of assessment u/s 147 beyond the limitation period, involving the addition of cash deposits in the assessee's savings bank...

Faceless assessment of income escaping assessment challenged due to non-compliance with Section 151A. Notices issued by Joint Assessing Officer (JAO) instead of Faceless...

Assessment u/s 147 versus 153C - choice of correct course of assessment. The assessee's name featured in the list of beneficiaries of accommodation entries by way of...

Notices issued u/s 148 by Joint Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) were held invalid due to lack of jurisdiction, as per Section 151A...

Reopening of assessment u/s 147 v/s assessment u/s 153C - proceedings initiated u/s 132 - The correct course of reassessment is under section 153C not under section 147...

The ITAT Delhi held that the notice issued by a non-jurisdictional Assessing Officer u/s 148 was invalid. The jurisdiction over the assessee was with a different...

Reopening of assessment u/s 147 - AO jurisdiction in issuing notice - Once the territorial jurisdiction of respondent no.1 is admitted by the petitioner, there existed...

The court held that the Joint Assessing Officer (JAO) lacked jurisdiction to issue notices u/s 148 of the Income Tax Act for reassessment, as per Section 151A read with...

Quick Updates: