Reopening of assessment - change of opinion - Even de hors any ...

Case Laws Income Tax

October 10, 2023

Reopening of assessment - change of opinion - Even de hors any additional explanation by Petitioner, the wording and language of the notice and the order impugned herein itself reveals the distinct views taken by the AO. We find that the reopening of assessment is merely based on a change of opinion on the same set of facts and material before the AO which was available to him at the time of original assessment. - The order and notice quahsed - HC

View Source

← Previous Next →

Reopening of assessment - change of opinion - Even de hors any ...

Case Laws Income Tax

October 10, 2023

You may also like:

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...

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...

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 - Reason to believe - change of opinion - The reason we say that there is a change of opinion is because once a query has been raised...

Reopening of assessment u/s 147 - change of opinion - mechanical satisfaction - Admission of additional income by Senior Executive of the petitioner during the search -...

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

Validity of Reopening of assessment u/s 147 - When the primary facts necessary for assessment are fully and truly disclosed, the AO is not entitled on change of opinion...

Reopening of assessment u/s 147 - net loss of cancellation of forward contract - When the primary facts necessary for assessment are fully and truly disclosed, the AO is...

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...

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

Reopening of assessment - notice issued after the expiry of more than 4 years - Capitalization of interest income - The High Court observed that, the AO having raised a...

Reopening of assessment u/s 147 - Reason to believe - change of opinion - the reassessment is being resorted to only on account of ‘change of opinion’ of the Assessment...

Reopening of Assessment u/s 147 - change of opinion - By change of opinion holding that reduction towards reversal on account of cancellation and price revision and...

Reopening of assessment u/s 147 - change of opinion - when the primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not...

Quick Updates: