Validity of Reopening of assessment u/s 147 - we are of a strong ...

Reopening of assessment u/s 147 invalid due to mechanical sanction u/s 151; procedural failures noted.

February 26, 2022

Case Laws Income Tax AT

Validity of Reopening of assessment u/s 147 - we are of a strong conviction that the sanctioning authority, i.e, the Pr. Commissioner of Income-tax-II, Amritsar had granted his sanction u/s 151 of the Act, in a mechanical manner, i.e, without application of mind to the facts of the case and the material available on record. - AT

View Source

← Previous Next →

Validity of Reopening of assessment u/s 147 - we are of a strong ...

Reopening of assessment u/s 147 invalid due to mechanical sanction u/s 151; procedural failures noted.

February 26, 2022

Case Laws Income Tax AT

You may also like:

Reopening of assessment u/s 147 was invalid due to lack of valid sanction as required u/s 151. The competent authority must independently apply its mind based on...

Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval...

Reopening of assessment u/s 147 - Fresh sanction under Section 151 - For a moment, even if accept Revenue’s contention that the present proceedings are continuation of...

Reopening of assessment u/s 147 consequent to revision proceedings u/s 263 pending - notice u/s 148 issued during the pendency of the assessment proceedings following...

Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was...

Validity of Reopening of assessment u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with...

Reopening of assessment u/s 147 - Eligibility of reasons to believe - Entire recording of reasons to believe formed by the Assessing Officer were produced before the...

Reopening of assessment u/s 147 - Pr.CIT has recorded his satisfaction for reopening of the assessment in a most mechanical manner without considering even the...

Validity of Reopening of assessment u/s 147 - AO should not have issued notice without satisfying the condition precedent as laid down in clause (b) of section 149(1) of...

Validity of reopening of assessment u/s 147 - One wonders whether the sanctioning authority under Section 151 also would have even applied his mind because the reasons...

The High Court held that the jurisdictional facts necessary to invoke Section 147 for reassessment were absent. The reassessment was initiated after the four-year...

Reopening of assessment u/s 147 - sanction required u/s 151 has not been validly obtained - even while conveying the approval for re-opening, Addl.CIT has displayed...

Reopening of assessment - Grant of the sanction by the CIT u/s 151 of the Act, is not a mechanical act on his part but it requires due application of mind to the reasons...

Sanction by specified authority not obtained as per amended provisions of Section 151 for reopening assessment beyond 3 years, rendering impugned notice invalid;...

Reopening of assessment u/s 147 after 4 years - Validity of Sanction for issue of notice u/s 151 - respectfully following the aforesaid decision provisions of section...

Quick Updates: