Reopening of assessment u/s 147 - it appears that the AO has ...

Court Quashes Reopening of Assessment u/s 147; AO's Claims of Delay Unsupported by Evidence.

October 8, 2021

Case Laws Income Tax HC

Reopening of assessment u/s 147 - it appears that the AO has recorded to the effect that he could not refer the matter to the Transfer Pricing Officer nor could he examine the issue because of delayed submission of the revised reports - observations recorded by the AO are factually incorrect and contrary to the material evidence on record - while framing the assessment order, it would not reflect that due to non-submission of revised Accountant’s report or Form No.3CEB, AO could not determine the Arm’s Length Price or refer the issue to the Transfer Pricing Officer. - The notice is not sustainable, quashed - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - it appears that the AO has ...

Court Quashes Reopening of Assessment u/s 147; AO's Claims of Delay Unsupported by Evidence.

October 8, 2021

Case Laws Income Tax HC

You may also like:

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 - 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 was challenged. The Assessing Officer (AO) had disallowed 20% of total sundry creditors in the regular assessment u/s 143(3). The AO...

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 - 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...

Validity of reassessment proceedings u/s 147, the requirement of fresh tangible material for reopening assessment, and the disallowance of expenditure incurred on DAP,...

Validity of reopening of assessment u/s 147 - AO has not even made minimum exercise for ascertaining the unsecured loans accepted during the year, under consideration...

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...

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 after expiry of four years - Original assessment have been passed under section 143(3) on Dated 14.12.2011 and A.O. recorded...

The HC held that the AO lacked jurisdiction to reopen the assessment beyond four years u/s 147. The reasons did not establish the assessee's failure to fully disclose...

Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information...

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,...

HC quashed notice for reopening assessment under s.147 due to AO's failure to specify which material facts were not fully disclosed by petitioner. Court emphasized that...

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...

Quick Updates: