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1. Reopening of assessment u/s 147 - a plain reading of clause (ca) of Explanation 2 of Section 147 makes it clear that it cannot be gainsaid that Section 133C survey...

2. Reopening of assessment u/s 147 - period of limitation extended to 16 years vide Finance Act, 2012- validity of notice for the period which has been expired already...

3. Reopening of assessment u/s 147 - eligibility of reasons to believe - the foundation on which the AO based his belief that income chargeable to tax had escaped...

4. Formation of belief by the Assessing Officer that income has escaped assessment is the crux of the reopening provision. The reasons recorded must be based on tangible...

5. Reopening of assessment u/s 147 - time for issuance of notice under Section 148 - Individual identity of Section 148 as prevailing prior to amendment - applicability of...

6. Reassessment u/s 147 - fictitious F&O loss by manipulative client code modification - return was originally processed u/s 143(1) and notice u/s 148 was issued within...

7. Prior period expenditure - when prior period income is taxed prior period expenditure cannot be disallowed - AT

8. Reopening of assessment u/s 147 - ALV estimation - We are unable to see application of mind by the AO of the materials available before him. The AO has not recorded any...

9. The High Court held that the Assessing Officer could not reopen the assessment u/s 147 as the basic precondition of having "reason to believe" that income had escaped...

10. The case pertains to the assumption of jurisdiction u/ss 147/148 read with section 151 of the Income Tax Act. The Assessing Officer (AO) wrongly assumed jurisdiction u/s...

11. Reopening of assessment u/s 147 - operation of Section 148A - Effect of COVID pandemic and lock down - Extension of provisions of Section 148 which was prevailing prior...

12. Reopening of assessment u/s 147 - Individual identity of Section 148 as prevailing prior to amendment - applicability of the newly inserted provisions of Section 148A...

13. Reopening of assessment u/s 147 - Individual identity of Section 148 as prevailing prior to amendment - applicability of the newly inserted provisions of Section 148A...

14. Validity of reopening u/s 147 r.w.s. 148 - The Tribunal found that the reasons recorded by the Assessing Officer (AO) for reopening the assessment under section 147/148...

15. Provisions and requirements for reopening an assessment u/s 147 of the Income Tax Act, 1961, as amended. It emphasizes that mere 'change of opinion' without any new...