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

Case Laws Income Tax

February 15, 2022

Reopening of assessment u/s 147 - change of opinion - The impugned notice and the consequent action is legally unsustainable as the Revenue fails to satisfy the twin tests. Firstly, there is no assertion, much less material to indicate, that the income escaped assessment on account of failure on the part of the petitioner to disclose fully and truly all material facts necessary for the assessment, and, secondly, the reasons recorded by the Assessing Officer should not fall within the ambit of “mere change of opinion” on the very same material. - HC

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

Case Laws Income Tax

February 15, 2022

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