Home Highlights May 2014 Year 2014 This

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1. Reopening of assessment u/s 147 - reasons recorded on incorrect assumption of facts and non application of mind - possession of ITS information that the assessee has...

2. Revision u/s 263 - When the order of the AO suffers from a complete lack of enquiry, then the above said principle has no application due to the obvious reason that the...

3. Revision u/s 263 by CIT - difference arising in the revised return - taking a view should be backed by reasons and that reasons should be demonstrated in the order...

4. Reopening of assessment u/s 147 - The entire exercise of re-opening would depend upon the reasons recorded by the AO and therefore the reasons recorded to re-open the...

5. Revision u/s 263 - the AO also mentioned in the order that “The Documents as submitted by the assessee were examined and placed on record”, however no remark on the...

6. Reopening of assessment u/s 147 - AO has recorded the reasons after getting the information from the Directorate of Information New Delhi and applied his own mind in...

7. Revision u/s 263 by CIT - as per CIT AO had failed to verify applicability of the provisions of Section 56(2)(viia) - As far as the invocation of Explanation 2 to...

8. Revision u/s 263 - Applicability of provisions of 56(2)(vii)(b) - Documentary evidence available in the records which the AO admits to have verified the veracity thereof...

9. Revision u/s 263 - AO recorded in order that assessee had “duly furnished the details of opening stock, closing stock, sales and production i.e. consumption of paddy etc....

10. Reopening of assessment u/s 147 - share premium - As the reasons recorded does not quantify even an estimated amount of the alleged income which has escaped assessment...

11. Reopening of assessment u/s 147 - AO himself did not make addition in respect of the first part of the items of reason recorded - The addition made by the AO on the...

12. Reopening of assessment u/s 147 - There is a mistake in the reasons recorded for reopening and according to respondents it is a typographical error that the figure of...

13. Revision u/s 263 - lack of inquiry by AO - it is a case where the AO did not make any inquiry vis-à-vis the share premium and simply accepted the details filed by the...

14. Revision u/s 263 by CIT - reopening of assessment u/s 147 - "reason to suspect" v/s 'reason to believe' - Information adverse may trigger "reason to suspect" and not...

15. Revision u/s 263 - As the assessment was completed after making required amount of enquiry and there was no lake of enquiry or investigation by the AO on the issues...