Reopening of assessment u/s 147 - Notice after four years - ...

Income Tax Officer must independently verify audit objections u/s 147; notice quashed, admitted tax liability payable.

January 29, 2022

Case Laws Income Tax HC

Reopening of assessment u/s 147 - Notice after four years - reopening based on audit objections - The Income Tax Officer must determine for himself what is the effect and consequence of the law mentioned in the audit note and whether in consequence of the law which has come to his notice he can reasonably believe that income had escaped assessment. The basis of his belief must be the law of which he has now become aware. - Further there is nothing under this head to indicate that there was failure on the part of petitioner to truly and fully disclose any fact - Notice and order quashed - however admitted liability of tax by the assessee directed to be paid - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - Notice after four years - ...

Income Tax Officer must independently verify audit objections u/s 147; notice quashed, admitted tax liability payable.

January 29, 2022

Case Laws Income Tax HC

You may also like:

The case pertains to the reopening of assessment u/s 147, where the reasons recorded were based on audit objections raised by the internal audit party regarding...

The High Court examined the jurisdiction of the Assessing Officer (AO) and the prescribed income-tax authority to issue notices u/s 143(2) of the Income Tax Act. It held...

Reopening of assessment u/s 147 was invalid due to procedural irregularities. The Assessing Officer initiated proceedings without verifying information and the...

Reopening of assessment u/s 147 - Rejection of objections of the assessee - The stance of the Assessing Officer leads this Court to prima facie believe that the...

Reopening of assessment u/s 147 - It is settled law that the opinion of the Internal Audit party of the Income Tax Department cannot be recorded as information within...

Reopening of assessment u/s 147 - reply to the audit objections - in fact AO applied his mind to the audit party objection and formed a clear opinion that there is no...

Reopening of assessment u/s 147 - it is evident that assessing officer has para-wise dealt with the objections of the appellant. We do not feel the need to delve into...

Rectification of mistake u/s 154 - AO issued notice u/s 154 based on audit objections, adding waiver of principal amount and revising book profit. Tribunal dismissed...

HC quashed reassessment proceedings under s.147 initiated after four years. AO's reasons revealed information was derived from original assessment documents, indicating...

Reopening of assessment u/s 147 - Addition on different ground - the Assessing Officer has accepted the objections of the assessee, and has not assessed or reassessed...

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...

The High Court held that the reassessment proceedings initiated by the Assessing Officer based on an audit objection were invalid. The Court observed that the Assessing...

Reopening of assessment u/s 147 - validity of order passed u/s 148A(d) - With Regard to the approval under Section 151 of the Income Tax Act, the High Court questions...

Income-tax Officer (Intelligence) authority to issue notice u/s 133(6) - Jurisdiction of Income Tax Authorities u/s 120 - From the reliance on the notification dated...

Reopening of assessment u/s 147 - Reasons to believe or suspect - huge share transaction - The court held that the reasons provided by the Assessing Officer for...

Quick Updates: