Home Highlights March 2019 Year 2019 This

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1. Validity of reopening of assessment u/s 147 - In the instant case the primary facts were already disclosed in the Notes to Accounts filed along with the balance-sheet...

2. 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...

3. Reopening of assessment u/s 147 - Eligibility of reasons to believe - there is nothing new and it is, in fact, the very note filed by the assessee as well as material...

4. 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...

5. 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...

6. Validity of reopening of assessment - It is well settled Law that validity of the reassessment proceedings is to be judged with reference to the reasons recorded for...

7. Validity of Initiation of proceedings u/s 153C - as argued satisfaction note of the searched person and satisfaction note of the petitioner (other than the searched...

8. Reopening of assessment u/s 147 - When the A.O. admits in the notice under section 142(1) Dated 20.10.2014 that assessee filed return of income under section 148 of the...

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. Validity of reopening assessment u/s 147 - the reopening of assessment made by the AO on irrelevant facts and on a mere reason to suspect cannot survive. We hold that...

11. Revision u/s 263 - Scope of the affidavit relief upon by the AO - It is not self serving affidavit of the assessee but of concerned party from whom allegedly the...

12. 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...

13. 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...

14. Reopening of assessment u/s 147 - Unexplained loan - There were no justification for the A.O. to record non-existing, incorrect and wrong facts in the reasons for...

15. 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...