Home Highlights November 2017 Year 2017 This

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1. Reopening of assessment u/s 147 - The High Court noted that the issue of disallowance under Section 14A of the Act had been thoroughly examined during the original...

2. 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,...

3. 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...

4. Reopening u/s 147 - original assessment u/s 143(3) - notice issued within 4 year - specific queries were raised in original assessment proceedings, which were duly...

5. 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...

6. Reopening of assessment u/s 147 - Reasons to believe - The ITAT thoroughly examined the reasons recorded by the AO for re-opening the assessment and found that there was...

7. Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in...

8. Validity of reopening of assessment u/s 147 - AO has not even made minimum exercise for ascertaining the unsecured loans accepted during the year, under consideration...

9. Reopening of assessment u/s 147/148 - failure to issue notice u/s 143(2) - reopening of assessment is not valid as the Income Tax Department has power to conduct the...

10. Reopening of assessment u/s 147 - reopening after expiry of four years - Original assessment have been passed under section 143(3) on Dated 14.12.2011 and A.O. recorded...

11. Reopening of assessment u/s 147 - Addition u/s 68 - unexplained share premium - While recording the reasons for reopening the assessment, the AO did not even care to...

12. Reopening of assessment - Jurisdiction of AO - AO, Mumbai who has issued the notice u/s 148 was not having jurisdiction as only AO, Dehradun was having the jurisdiction...

13. Reopening of assessment u/s 147 - Once a query has been raised by Assessing Officer through the assessment proceeding and the assessee has responded to that query, it...

14. Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted...

15. 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...