Validity of Reopening of assessment u/s 147 - to say that the ...

Case Laws Income Tax

January 22, 2022

Validity of Reopening of assessment u/s 147 - to say that the assessee had concealed any material fact relating to EDC, is not correct. That he had reflected it is as a liability in the Balance Sheet and not shown it as revenue receipt in its Profit & Loss Account, is not a matter of fact but on the contrary it is an interpretation of the fact of receipt of EDC regarding its nature and the reasons do not bring out any material /information with the AO leading him to form this opinion of the EDC charges being Revenue in nature. DR has been unable to enlighten us as to what material fact relating to EDC was concealed by the assessee so as to empower the AO to assume jurisdiction to reopen the case of the assessee beyond four years from the relevant assessment year. - AT

View Source

← Previous Next →

Validity of Reopening of assessment u/s 147 - to say that the ...

Case Laws Income Tax

January 22, 2022

You may also like:

The crux of the matter revolves around the reopening of assessment u/s 147 of the Act and the addition made u/s 68 treating the share application received as a...

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...

Reopening of assessment u/s 147 was based on reasons to believe the difference between total cash sales and cash sales reflected in books. Held: Reopening was made only...

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...

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 - reason to believe - there was tangible material before the AO to reopen the concluded assessment as the assessee is claiming huge...

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...

Reopening of assessment u/s 147 - while reopening no allegation was made by the learned AO of failure on the part of the assessee to disclose fully and truly all...

Reopening of assessment u/s 147 - The writ-applicant has claimed deduction under Section 35(1)(ii) of the Act and not under Section 80GGA of the Act. This fact is also...

Reopening of assessment u/s 147 - the very basis of reopening of assessment is based on incomplete or wrong facts available on record as the said transaction of sale of...

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 - necessary conditions for initiating and completion - the reopening of the assessment made by the learned assessing officer is not on...

Validity of reopening of assessment u/s 147 - Addition u/s 68 - The function of the assessing authority at this stage is to administer the statute and what is required...

Validity of reopening assessment u/s 147 challenged. Profit earned by trading in shares treated as unexplained credit u/s 68. Held: Petitioner disclosed all material...

Validity of reopening of assessment u/s 147 - reasons to believe - increase in share capital - There was no allegation that there is any failure on the part of the...

Quick Updates: