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 February 2022 Year 2022 This

Validity of reopening of assessment u/s 147 - assumption of ...

Income Tax

February 1, 2022

Validity of reopening of assessment u/s 147 - assumption of jurisdiction by the ld. AO u/s.147 - He had categorically stated in the reasons that from the records these transactions were found. That itself goes to prove that the ld. AO had gone into the assessment records again and had sought to entertain the change of opinion on the same set of facts available in the records.Hence, the reopening of assessment in respect of capital gain on sale of TCS Ltd. shares and re-investment in preference shares of Tata Sons Ltd., is declared as bad in law. - AT

View Source

 


 

You may also like:

  1. Jurisdiction by AO to suo-moto convert protective assessment into substantive assessment post completion of original assessment proceedings - Once the ld CIT(A) was...

  2. Reopening of assessment u/s 147 - time to initiate Revision u/s 263 was not left - Reopening is made at the direction of the ld. CIT. The ld. CIT when he did not find...

  3. Validity of Reopening of assessment u/s 147 - When the primary facts necessary for assessment are fully and truly disclosed, the AO is not entitled on change of opinion...

  4. Reopening of assessment u/s 147 - addition u/s 68 - The law regarding reopening of assessment is well-settled. The reliance placed upon the findings of the earlier...

  5. Validity of reopening u/s 147 r.w.s. 148 - The Tribunal found that the reasons recorded by the Assessing Officer (AO) for reopening the assessment under section 147/148...

  6. Reopening of assessment - Reason to belief - Addition u/s 69 was made in assessment u/s 143(3) r.w.s 153A - if such income has already been assessed then the AO could...

  7. 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...

  8. Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not...

  9. Validity of reopening of assessment u/s 147 - beyond 4 years but within 6 years - Report of the investigation wing might constitute tangible material. The decision to...

  10. Reopening of assessment u/s 147 - When the income is foundation on which he based his belief of escapement of income is absent, so AO's usurpation of jurisdiction to...

  11. Validity of reopening of assessment u/s 147 - AO has not even made minimum exercise for ascertaining the unsecured loans accepted during the year, under consideration...

  12. Reopening of assessment u/s 147 - Non–disposal of objections challenging the validity of re–opening of assessment u/s 147 is not a mere procedural lapse but effects the...

  13. Reopening of assessment u/s 147 - - reopening based on report of the Investigation Wing - Assessing officer can rely on the report of DIT, Investigation Wing but at the...

  14. Validity of Reopening of assessment u/s 147 - requirement of recording of “reasons to believe” - validity of jurisdiction assumed by the AO for reopening the case of the...

  15. 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...

 

Quick Updates:Latest Updates