Reopening of assessment u/s 147 - excessive share premium - The ...

Case Laws Income Tax

February 3, 2024

Reopening of assessment u/s 147 - excessive share premium - The High Court observed that, the reopening of an assessment requires a valid "reason to believe" based on new tangible material, not merely a change of opinion or directives from higher authorities. Additionally, share premium received on issuance of fresh shares is considered a capital receipt, not income, and thus not taxable under the Act for the assessment year in question.

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Reopening of assessment u/s 147 - excessive share premium - The ...

Case Laws Income Tax

February 3, 2024

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