Home Highlights June 2014 Year 2014 This

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1. Reopening of assessment u/s 147 - Initiation of reassessment proceedings, u/s.148 of the Act and issued notice to the assessee was based on valid reason on the strength...

2. Validity of reopening of assessment u/s 147 - Reason to believe - The Appellate Tribunal observed that the reassessment proceedings were initiated solely based on the...

3. Reopening of assessment u/s 147 - unexplained share application money - non independent application of mind by AO - In the present case also since the AO acted upon the...

4. Reopening of assessment u/s 147 v/s assessment u/s 153C - proceedings initiated u/s 132 - The correct course of reassessment is under section 153C not under section 147...

5. Reopening of assessment u/s 147 - unexplained cash payment - Two notices issued u/s 148 - it is a case where pending conclusion of the first reassessment proceedings,...

6. Once the case of reassessment is made out by the AO which falls in the preview of specific provisions of section 153C of the Act, the AO cannot resort to invoke the...

7. Reopening of assessment u/s 147 - Earlier, ITAT remanded the matter back requesting the AO to provide reasons for initiating reassessment proceedings. - AO must have...

8. Reopening of assessment u/s 147 - The application of mind by the AO to the new and tangible material has to be discerned from the reasons recorded in each case and from...

9. Validity of the assessment order passed u/s 147 r.w.s. 143(3) - post search assessment - in the case on hand the pending reassessment proceedings u/s 147 got abated by...

10. Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147...

11. So long as the ingredients of section 147 are fulfilled, the AO is free to initiate proceeding u/s 147 and failure to take steps u/s 143(3) will not render the AO...

12. Validity of Reopening of assessment u/s 147 - When the primary facts necessary for assessment are fully and truly disclosed, the AO is not entitled on change of opinion...

13. Reopening of assessment u/s 147 - net loss of cancellation of forward contract - When the primary facts necessary for assessment are fully and truly disclosed, the AO is...

14. Reopening of assessment u/s 147 or 153C - assessment proceedings were initiated mainly on the information found during the search proceedings - jurisdiction lies to...

15. Reopening of assessment u/s 147 - As reopening of the assessment has been made on the basis of AIR information which is not based on correct facts and the AO has not...