Reopening of assessment u/s 147 - Transfer of case u/s 127 - ...

Court Challenges Reopening of Assessment Due to Incorrect Jurisdictional Assumptions u/s 147 and Transfer u/s 127.

November 13, 2021

Case Laws Income Tax AT

Reopening of assessment u/s 147 - Transfer of case u/s 127 - There is no nexus between the material coming to the notice of the AO and the formation of his belief that there has been escapement of income. The amount in the bank account with HSBC Geneva is not relating to the assessment years under consideration. Hence, the very basis for assuming jurisdiction is not factually correct, no reasonable belief can be formed based on such incorrect facts. - AT

View Source

← Previous Next →

Reopening of assessment u/s 147 - Transfer of case u/s 127 - ...

Court Challenges Reopening of Assessment Due to Incorrect Jurisdictional Assumptions u/s 147 and Transfer u/s 127.

November 13, 2021

Case Laws Income Tax AT

You may also like:

Validity of reopening assessment challenged due to non-disposal of objections raised by assessee against reassessment. Deduction u/s 24(a) proposed to be disallowed....

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...

The High Court quashed the reopening notice issued by the Assessing Officer u/s 148 for reassessment beyond the period of four years. The assessee had filed returns...

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 - Unexplained loan - There were no justification for the A.O. to record non-existing, incorrect and wrong facts in the reasons for...

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...

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...

Validity of reopening of assessment - It is well settled Law that validity of the reassessment proceedings is to be judged with reference to the reasons recorded for...

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 - addition u/s 68 - The law regarding reopening of assessment is well-settled. The reliance placed upon the findings of the earlier...

Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based...

Reopening of assessment u/s 147 r.w.s. 148 - Participation in the assessment proceedings after rejection of objections by the AO, without challenging the order of...

Reopening of assessment u/s 147 - Reopening on the basis of the audit objections - the reasons for reopening of the assessment are almost identically worded as that of...

Reopening of assessment u/s 147 was challenged due to lack of material relating to alleged wrongful IGST refunds for assessment year 2020-21. Disallowable expenditure...

Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for...

Quick Updates: