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Income Tax - Highlights / Catch Notes

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Reopening of assessment u/s 147 - validity of reasons to believe ...


Reassessment u/s 147 Invalid Due to Change of Opinion Without New Material by Assessing Officer.

July 16, 2021

Case Laws     Income Tax     AT

Reopening of assessment u/s 147 - validity of reasons to believe - the reassessment proceeding under section 147 has not been validly initiated because the same has been initiated merely on a change of opinion without any fresh material coming into the possession of the AO - The reason must have live link with the formation of the belief. - AT

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