Reopening of assessment u/s 147 - There is a mistake in the ...

High Court Quashes Assessment Reopening: Error in Recorded Amount and Lack of Approval u/ss 147 and 151.

January 13, 2022

Case Laws Income Tax HC

Reopening of assessment u/s 147 - There is a mistake in the reasons recorded for reopening and according to respondents it is a typographical error that the figure of ₹ 3.02 lakhs was mentioned instead of ₹ 293.24 lakhs. In our view, this mistake demonstrates non-application of mind by respondent No.1 at the time of recording of the reasons for reopening the assessment. Though we do not find the approval under section 151 of the Act in the record and proceedings, we can certainly hazard a guess that even the Approving Authority would not have applied its mind or read the reasons recorded before granting approval. - Notice quashed - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - There is a mistake in the ...

High Court Quashes Assessment Reopening: Error in Recorded Amount and Lack of Approval u/ss 147 and 151.

January 13, 2022

Case Laws Income Tax HC

You may also like:

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

Reopening of assessment u/s 147 - Pr.CIT has recorded his satisfaction for reopening of the assessment in a most mechanical manner without considering even the...

The case pertains to the assumption of jurisdiction u/ss 147/148 read with section 151 of the Income Tax Act. The Assessing Officer (AO) wrongly assumed jurisdiction u/s...

Validity of Reopening of assessment u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with...

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 - no approval was taken U/s 151 - The tribunal found that the notice issued under section 148/143(3) lacked proper approval under...

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...

Reopening of assessment u/s 147 - There is no indication of any application of mind by the authority. Moreover, the approval under Section 151 of the Act had to be...

Reopening of assessment u/s 147 - Validity of approval granted u/s 151 - without examining the facts on record, both the Additional CIT and CIT have granted approval...

HC upheld validity of assessment order under s.147 read with s.144B, finding proper approval under s.151. Court confirmed Range Head and CIT/PCIT had appropriately...

Reopening of assessment u/s 147 - recording of satisfaction in mechanical manner - PCIT also mechanically issued permission to reopen the assessment without going into...

The ITAT Delhi held that the reopening of assessment u/s 147 was invalid as the JCIT granted approval mechanically without proper application of mind. The JCIT's...

Validity of reopening of assessment u/s 147 - appropriate authority - if Joint Commissioner approves the proceedings/ proposal sent by the Assessing Officer to be a fit...

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...

Quick Updates: