Home Highlights February 2016 Year 2016 This

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1. Validity of reopening of assessment u/s 147 - beyond 4 years but within 6 years - Report of the investigation wing might constitute tangible material. The decision to...

2. Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit...

3. Reopening of assessment u/s 147 - the notice u/s 148 on the basis of “on verification of records” - the AO has power to reopen the assessment, provided there is...

4. Reopening of assessment u/s 147 - AO has reasons to believe that such payments which were not considered during the original assessment escaped assessment and therefore,...

5. Reopening of assessment u/s 147 r.w.s. 148 - We reject the argument of AR that even in the case where there is no assessment made by the AO or the return is processed...

6. Reopening of assessment u/s 147 - reason to believe - there was tangible material before the AO to reopen the concluded assessment as the assessee is claiming huge...

7. Reopening of assessment u/s 147 - Reasons to believe - It is not the case of the revenue that, subsequently i.e. after the order of scrutiny assessment, the assessing...

8. Reopening of assessment u/s 147 - Mere production of books of account and the details by the assessee are one aspect of the matter and even with reference to such books...

9. Reopening of assessment u/s 147 - there is prima facie tangible material to form an opinion that the income has escaped assessment and the assessee failed to disclose...

10. Reopening of assessment u/s 147 - necessary conditions for initiating and completion - the reopening of the assessment made by the learned assessing officer is not on...

11. Reopening of assessment u/s 147 - The writ-applicant has claimed deduction under Section 35(1)(ii) of the Act and not under Section 80GGA of the Act. This fact is also...

12. Reopening of assessment u/s 147 - As examined the belief of the Assessing Officer to a limited extent to look into whether there was sufficient or any tangible materials...

13. Reopening of assessment u/s 147 - Reasons to believe - When the AO has not created any link between tangible material and the formation of reason to believe that income...

14. Reopening of assessment u/s 147 - In case incorrect, wrong and non-existing reasons are recorded by the A.O. for reopening of the assessment and A.O. failed to verify...

15. Reopening of assessment u/s 147 - ‘reasons to believe’ and ‘reasons to suspect’ - Merely on the basis of suspicion observed that the aforesaid entry might be a bogus...