Reopening of assessment u/s 147 - protective addition - Neither ...

Court Upholds CIT (A)'s Decision: Reopening of Assessment u/s 147 for Protective Addition Deemed Unjustified.

August 3, 2021

Case Laws Income Tax AT

Reopening of assessment u/s 147 - protective addition - Neither at the time of recording the reasons, nor at the time of framing the assessment, AO was’nt sure about whose income has escaped assessment. We do not find any reason to interefere with the findings of the CIT (A) that reopening for resorting to make protective assessment cannot be upheld - AT

View Source

← Previous Next →

Reopening of assessment u/s 147 - protective addition - Neither ...

Court Upholds CIT (A)'s Decision: Reopening of Assessment u/s 147 for Protective Addition Deemed Unjustified.

August 3, 2021

Case Laws Income Tax AT

You may also like:

Absence of incriminating material during search precludes additions in completed assessments, as per Supreme Court's ruling in Principal Commissioner of Income-tax,...

Reopening of assessment u/s 147 - Reopening based on audit objections - reasons to believe - High Court observed that, reopening an assessment beyond four years requires...

The crux of the matter revolves around the reopening of assessment u/s 147 of the Act and the addition made u/s 68 treating the share application received as a...

Validity of reopening assessment u/s 147 regarding undisclosed foreign bank account income examined. Non-providing sufficient opportunities and violation of principles...

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...

Reopening of assessment u/s 147 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion...

Reopening of assessment u/s 147 - It is sufficient if any one of the conditions stipulated in Proviso clause to Section 147 is satisfied for reopening of assessment. -...

Reopening of assessment u/s 147 - deemed dividend addition u/s 2(22)(e) - gap of more than four years - when the amount received by the two concerns from the loan giver...

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...

Section 147 allows reopening of assessments in exceptional cases where the Assessing Officer has reason to believe income has escaped assessment. Concluded assessments...

Reopening of assessment u/s 147 - In case incorrect, wrong and non-existing reasons are recorded by the A.O. for reopening of the assessment and A.O. failed to verify...

Reopening of assessment u/s 147 - No addition being loan given forming the main `reason for escapement of income’ u/s 147 of the Act has been made by the AO and instead,...

Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening...

Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the...

Reopening of assessment u/s 147 - This being the scope of Section 147 for reopening of assessment, this Court do not find any acceptable reason for the purpose of...

Quick Updates: