Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights December 2021 Year 2021 This

Validity of reopening of assessment u/s 147 - In the instant ...


Reassessment u/s 147 Invalid: Facts Disclosed in Notes to Accounts, No Failure in Disclosure Found.

December 14, 2021

Case Laws     Income Tax     AT

Validity of reopening of assessment u/s 147 - In the instant case the primary facts were already disclosed in the Notes to Accounts filed along with the balance-sheet which is the subject matter of reopening of the assessment and since the original assessment was completed under section 143(3) and since there is no allegation by the A.O. of any failure on the part of the assessee to disclose fully and truly all material facts necessary for completion of the assessment - reassessment proceedings initiated by the A.O. in the instant case after a period of four years from the relevant assessment year are not in accordance with Law. - AT

View Source

 


 

You may also like:

  1. HC quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts...

  2. Reopening of assessment u/s 147 - The High Court noted that the extended period of six years for reassessment could only be invoked under specific circumstances, one of...

  3. The High Court held that the jurisdictional facts necessary to invoke Section 147 for reassessment were absent. The reassessment was initiated after the four-year...

  4. The ITAT allowed the assessee's appeal against the reopening of assessment u/s 147 beyond the four-year period. The Assessing Officer failed to record a finding that the...

  5. The ITAT Nagpur considered the validity of reassessment proceedings u/s 147. The AO issued notice beyond four years alleging capital gain on "Sale of Vehicles" escaped...

  6. Reopening of assessment u/s 147 was invalid as Assessing Officer (AO) failed to record that assessee did not disclose fully and truly all material facts necessary for...

  7. The High Court held that the reassessment proceedings initiated by the Revenue were invalid due to the absence of any failure on the part of the assessee to disclose...

  8. Reopening of assessment after expiry of four years due to deemed dividend u/s 2(22)(e) was found invalid. The Assessing Officer (AO) failed to establish that the...

  9. Validity of Reopening of assessment u/s 147 - The Tribunal emphasized the principle that for reassessment under Section 147 of the Income Tax Act, the onus is on the...

  10. The ITAT Kolkata examined the validity of reassessment proceedings based on "reasons to believe" u/s 147. The AO's reasons lacked independent application of mind, being...

  11. Reopening of assessment - reason to believe - The Court evaluates the concept of "true and full disclosure" as mandated by Section 147, considering relevant legal...

  12. HC quashed reassessment notices and order finding them invalid under Section 147 of Income Tax Act. Notices issued after four years were without fresh material...

  13. Reopening of assessment u/s 147 - extension of period of limitation u/s 147 - In this case, failure on the part of the assessee to fully and truly disclose all material...

  14. Reassessment u/s 147/148 - Initiation of rectification u/s 154 by the AO and simultaneously initiating the reassessment u/s 147/148 on the same reasons, particularly...

  15. HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to...

 

Quick Updates:Latest Updates