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Income Tax - Highlights / Catch Notes

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Validity of reopening of assessment u/s 147 - reason to believe ...


Invalid Reopening of Tax Assessment Due to Improper Use of Information and Change of Opinion.

November 12, 2023

Case Laws     Income Tax     HC

Validity of reopening of assessment u/s 147 - reason to believe - As prima-facie the information which formed the basis of re-opening itself does not fall within the meaning of the term ‘information’ under the 1st Explanation to Section 148 of the Act and hence, the re-opening is not permissible as it clearly falls within the purview of a ‘change of opinion’ which is impermissible in law. - HC

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