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 October 2023 Year 2023 This

Validity of Reopening of assessment u/s 147 - Failure to record ...

Case Laws     Income Tax

October 11, 2023

Validity of Reopening of assessment u/s 147 - Failure to record the valid satisfaction - The assessment order passed, as a consequence is, liable to quashed. The contention of the ld. DR that there was a separate reasons recorded by the AO which revealed the source of information or the material with the AO leading to his belief of escapement of income, is of no assistance to the validity of the re-assessment proceedings, since admittedly, this reason was never confronted to the assessee. - AT

View Source

 


 

You may also like:

  1. 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...

  2. Assessment u/s 153C - satisfaction on the basis of the borrowed information - It is true that the supreme Court has made the said observations while considering the...

  3. The Appellate Tribunal held that the assessment orders issued u/s 153C for the assessment years 2011-12 and 2012-13 were beyond the jurisdiction of the Assessing Officer...

  4. Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT (Inv.) - The repetition of certain portions of the investigation...

  5. Reopening of assessment u/s 147/148 - failure to issue notice u/s 143(2) - reopening of assessment is not valid as the Income Tax Department has power to conduct the...

  6. 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...

  7. 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...

  8. Validity of reopening of assessment u/s 147 - assumption of jurisdiction by the ld. AO u/s.147 - He had categorically stated in the reasons that from the records these...

  9. Validity of re-assessment proceedings initiated u/s.148 - If the reasons recorded are silent or there is no reference of any material, then other extraneous material...

  10. Validity of reopening of assessment u/s 147 - assessment beyond a period of 4 years - mandation of recording satisfaction - The satisfaction as contemplated u/s 151 of...

  11. Validity of reopening of assessment - proceeding u/s 147 initiated on the basis of satisfaction note recorded u/s 153C - curable defect u/s 292B - not challenging before...

  12. Validity of reopening of assessment - It is well settled Law that validity of the reassessment proceedings is to be judged with reference to the reasons recorded for...

  13. Reopening of assessment u/s 147 was invalid as Assessing Officer (AO) failed to record that assessee did not disclose fully and truly all material facts necessary for...

  14. Reopening of assessment u/s 147 - recording of satisfaction in mechanical manner - PCIT also mechanically issued permission to reopen the assessment without going into...

  15. 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. -...

 

Quick Updates:Latest Updates