Reopening of assessment u/s 147 - change of opinion - mechanical ...

Case Laws Income Tax

March 2, 2024

Reopening of assessment u/s 147 - change of opinion - mechanical satisfaction - Admission of additional income by Senior Executive of the petitioner during the search - variation in additional income admitted - The High Court upheld the justification for reopening provided by the respondents, highlighting the availability of fresh material and alleged failures by the petitioners to fully disclose material evidence. Objections regarding change of opinion and mechanical satisfaction were rejected.

View Source

← Previous Next →

Reopening of assessment u/s 147 - change of opinion - mechanical ...

Case Laws Income Tax

March 2, 2024

You may also like:

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 - 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...

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 the assessment u/s 147 - Reason to believe - change of opinion - merely because another director of the same company had disclosed the income received...

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...

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...

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...

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...

The assessment order was challenged on the grounds of validity of reopening after four years, based on a change of opinion and borrowed satisfaction. The assessee...

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...

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...

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...

Reopening of assessment u/s 147 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion...

Quick Updates: