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 January 2023 Year 2023 This

Reopening of assessment u/s 147 - in the original regular ...


Reopening of 2014-15 assessment u/s 147 challenged; petitioner argues full disclosure of Wipro shares was made initially.

January 9, 2023

Case Laws     Income Tax     HC

Reopening of assessment u/s 147 - in the original regular assessment proceedings for the subject assessment year 2014-15, the Assessing Officer had sought for and examined the petitioner’ share demat account which was provided by the petitioner to the Assessing Officer furnishing all particulars regarding the Wipro shares; this circumstance is also a pointer to the fact that the Assessing Officer had complete and full knowledge of the subject shares and their value at the time of original assessment proceedings and on this score also, it cannot be said that the income of the petitioner had escaped assessment due to failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment and consequently, the impugned order deserves to be quashed on this ground also. - HC

View Source

 


 

You may also like:

  1. The assessee's claim for deduction u/s 80IC for the finished products manufactured at Unit No. III at Paonta Sahib, Himachal Pradesh, was initially allowed but later...

  2. Validity of reopening of assessment u/s 147 - A copy of the audit objection reveals that because for the subsequent year, i.e., AY 2014- 15, the Department had not...

  3. Reopening of assessment u/s 147 - The duty is cast upon the assessee to make true and full disclosure of the facts at the time of original assessment. The duty of the...

  4. Reopening of assessment - reason to believe - The Court evaluates the concept of "true and full disclosure" as mandated by Section 147, considering relevant legal...

  5. HC invalidated reassessment proceedings under s.147 for AY 2014-15 initiated beyond four years. AO failed to demonstrate any failure by assessee to fully disclose...

  6. Reopening of assessment u/s 147 - Addition u/s 68 - unexplained share premium - While recording the reasons for reopening the assessment, the AO did not even care to...

  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 - The two situations are distinct and different. Thus, where the transaction itself on the basis of the subsequent information, is found...

  9. The HC held that the period of limitation for reopening assessments under Section 153C read with Section 153A must be calculated from the end of the assessment year...

  10. Reopening of assessment u/s 147 - Validity of order u/s 148A - all such notices when they would relate to Assessment Year 2013-14 or Assessment Year 2014-15 would be...

  11. Reopening of assessment u/s 147 - Validity of order u/s 148A - all such notices when they would relate to Assessment Year 2013-14 or Assessment Year 2014-15 would be...

  12. Reopening of assessment u/s 147 - reopening after expiry of four years - Original assessment have been passed under section 143(3) on Dated 14.12.2011 and A.O. recorded...

  13. A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not...

  14. Reopening of assessment u/s 147 - Change of opinion - As has always been observed, notice under Section 147 is not to be casually invoked to suit the convenience of the...

  15. Reopening of assessment u/s 147 - Addition u/s 14A read with Rule 8D. "Reason to believe" in Section 147 means cause or justification for the competent authority to...

 

Quick Updates:Latest Updates