Reopening of assessment u/s 147 - sufficiency or inadequacy of ...

Court Rules: No Grounds for Reopening Tax Assessment u/s 147 Due to Mere Change of Opinion.

January 5, 2023

Case Laws Income Tax HC

Reopening of assessment u/s 147 - sufficiency or inadequacy of reasons - There is no whisper in the impugned order as regards any failure on the part of petitioner to disclose fully and truly all material facts and as such it is not possible for this Court to infer any such failure on the part of the assessee from the reasons recorded. Petitioner had made adequate disclosures during assessment proceedings which is now sought to be reopened and particularly with reference to ground Nos.1 and 2 on which the respondent authority has proposed to reopen the assessment - change of opinion cannot be the basis for reopening the assessment. - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - sufficiency or inadequacy of ...

Court Rules: No Grounds for Reopening Tax Assessment u/s 147 Due to Mere Change of Opinion.

January 5, 2023

Case Laws Income Tax HC

You may also like:

The High Court held that the Assessing Officer cannot reopen the assessment u/s 147 merely based on a change of opinion. The assessee had fully and truly disclosed all...

Reopening of assessment u/s 147 was challenged on the ground of mere change of opinion. The assessee had filed return claiming deduction u/s 80IC and furnished all...

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...

Validity of reopening an assessment u/s 147 of the Income Tax Act, the distinction between "change of opinion" and "reasons to believe," and the classification of income...

Reopening of assessment u/s 147 was challenged. The Assessing Officer (AO) had disallowed 20% of total sundry creditors in the regular assessment u/s 143(3). The AO...

Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based...

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 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion...

Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for...

The High Court held that the Assessing Officer (AO) could not reopen the assessment merely based on a belief that the average gross profit in the assessee's business...

Reopening of assessment u/s 147 - The High Court dismissed the appeal filed by the revenue, affirming the decision of the Income Tax Appellate Tribunal (ITAT) that...

The case pertains to the reopening of assessment u/s 147 of the Income Tax Act. The key points are: The department had already raised queries regarding the accumulation...

The High Court held that the reopening of assessment u/s 147 by the Assessing Officer (AO) was without jurisdiction and amounted to a mere change of opinion. The issue...

Reopening of assessment u/s 147 - Change of opinion - Once the assessee makes a true and full disclosure of the primary facts at the time of the original assessment and...

Reopening of assessment u/s 147 - reason to believe - commencement date / year for deduction u/s 80IA - Eligible from 1995 or 2000 - scope of change of opinion - We...

Quick Updates: