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 June 2023 Year 2023 This

Reopening of assessment u/s 147 - proper reasoning - Merely by ...


Reopening Tax Assessments Needs Solid Justification; Mere Claims of Non-Disclosure Insufficient u/s 147 Proviso.

June 13, 2023

Case Laws     Income Tax     AT

Reopening of assessment u/s 147 - proper reasoning - Merely by adding a line in the reasons recorded by the Assessing Officer that the assessee had failed to disclose fully and truly all material facts, requirement of proviso to section 147 of the Act would not be satisfied for the purpose of reopening of the assessment u/s 147 - AT

View Source

 


 

You may also like:

  1. Reopening of assessment u/s 147 - Unexplained loan - There were no justification for the A.O. to record non-existing, incorrect and wrong facts in the reasons for...

  2. Reopening of assessment u/s 147 - assessment after 4 years - reason to suspect OR reason to believe - Reopening of assessment which is already concluded under Section...

  3. Reopening of assessment - mere disclosure of transaction at the time of original assessment proceedings cannot be said to be a disclosure of the “true” and “full” facts...

  4. 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...

  5. The HC upheld the reopening of assessment under s.147 regarding two issues: (1) difference in rental figures between profit and loss account and AIR, and (2)...

  6. 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...

  7. 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...

  8. 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...

  9. 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...

  10. Reopening of assessment u/s 147 - In case incorrect, wrong and non-existing reasons are recorded by the A.O. for reopening of the assessment and A.O. failed to verify...

  11. 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...

  12. 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...

  13. Reopening of assessment u/s 147 - It is sufficient if any one of the conditions stipulated in Proviso clause to Section 147 is satisfied for reopening of assessment. -...

  14. The Assessing Officer (AO) reopened the assessment solely based on the information from a survey conducted by the Sales Tax Department, without independently examining...

  15. 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...

 

Quick Updates:Latest Updates