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Income Tax - Highlights / Catch Notes

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Reopening of assessment u/s 147 - concept of change of opinion - ...

Case Laws     Income Tax

February 14, 2022

Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a greater latitude to reopen the assessment. - AO had sufficient material at his command to form a belief that the income chargeable to tax has escaped assessment. There is a clear link between the information available with the assessing officer and his formation of belief that the income chargeable to tax has escaped assessment. - HC

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  10. 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...

  11. Validity of reopening of assessment u/s 147 - validity of reason to believe - during the scrutiny assessment, the case was discussed with the assessee on four dates,...

  12. Reopening of assessment u/s 147 - Reason to believe - change of opinion - The reason we say that there is a change of opinion is because once a query has been raised...

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