Reopening of assessment u/s 147 - sanction required u/s 151 has ...

Case Laws Income Tax

December 18, 2021

Reopening of assessment u/s 147 - sanction required u/s 151 has not been validly obtained - even while conveying the approval for re-opening, Addl.CIT has displayed non-application of mind. The non-approval is given for re-opening the assessment of Petitioner but in the reference it pertains to another entity and a communication dated 07/08/2017 is referred to. This also indicates that the Addl.CIT has granted sanction without even reading the letter. The notice under Section 148 has to be set aside and the same is hereby set aside - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - sanction required u/s 151 has ...

Case Laws Income Tax

December 18, 2021

You may also like:

Validity of reopening of assessment u/s 147 - One wonders whether the sanctioning authority under Section 151 also would have even applied his mind because the reasons...

Reopening of assessment u/s 147 - Fresh sanction under Section 151 - For a moment, even if accept Revenue’s contention that the present proceedings are continuation of...

Reopening of assessment u/s 147 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional...

Sanction by specified authority not obtained as per amended provisions of Section 151 for reopening assessment beyond 3 years, rendering impugned notice invalid;...

Reopening of assessment u/s 147 - Eligibility of reasons to believe - Entire recording of reasons to believe formed by the Assessing Officer were produced before the...

Reopening of Assessment – Claim of depreciation was not considered earlier - if there is no sanction as required under section 151 of the Act, the reopening would still...

Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was...

Reopening of assessment u/s 147 - Disallowance u/s 14A - If at all he has considered, he has not even passed the assessment order by ignoring the provisions of law, i.e....

Re-assessment u/s 147 - AO was clinched with tangible information in the shape of information from Sales Tax Authorities which prima-facie suggested possible escapement...

Reopening of assessment u/s 147 - Addition u/s 14A read with Rule 8D. "Reason to believe" in Section 147 means cause or justification for the competent authority to...

Validity of Reopening of assessment u/s 147 - AO should not have issued notice without satisfying the condition precedent as laid down in clause (b) of section 149(1) of...

Reopening of assessment u/s 147 after 4 years - Validity of Sanction for issue of notice u/s 151 - respectfully following the aforesaid decision provisions of section...

Reopening of assessment u/s 147 was invalid due to lack of valid sanction as required u/s 151. The competent authority must independently apply its mind based on...

Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following...

Reopening of assessment u/s 147 - There is complete non application of mind on the part of Joint CIT, Range 5(3), Mumbai, while granting sanction under section 151 of...

Quick Updates: