Reopening of assessment u/s 147 - There is no gainsaying that ...

Case Laws Income Tax

September 10, 2021

Reopening of assessment u/s 147 - There is no gainsaying that the Courts declare the law and do not legislate. With the advent of Engineering Analysis (SC) (supra), the law since inception has to be presumed as not treating the sale of software licenses as ‘Royalty’ in terms of section 9(1)(vi) read with Article 12 of the DTAA insofar as the year under consideration is concerned. Thus, the re-assessment pursuant to such reasons is hereby set-aside. - AT

View Source

← Previous Next →

Reopening of assessment u/s 147 - There is no gainsaying that ...

Case Laws Income Tax

September 10, 2021

You may also like:

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...

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

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 - reply to the audit objections - in fact AO applied his mind to the audit party objection and formed a clear opinion that there is no...

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...

The High Court addressed the issue of reopening assessment u/s 147 of the Income Tax Act. The case involved the alleged absence of a "reason to believe" and a "live...

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. -...

Validity of reopening of assessment u/s 147 - assumption of jurisdiction by the ld. AO u/s.147 - He had categorically stated in the reasons that from the records these...

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 - Period of limitation - The audit party is entitled to point out a factual error or omission in the assessment. reopening of the...

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 - Non dealing with objections - In the present case, apart from the fact that the reopening of the assessment being bad in law for...

Reopening of assessment u/s 147 - second re-assessment notice u/s 148A - The High Court noted that the petitioner did not challenge the earlier re-assessment order dated...

Reopening of assessment u/s 147 - Reasons to believe or suspect - huge share transaction - The court held that the reasons provided by the Assessing Officer for...

Quick Updates: