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1. 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...

2. Reopening of assessment u/ 147 - Revenue has to prima facie indicate as to which of the conditions of Section 10(10D) of the Act are not fulfilled. In other words, how...

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 of assessment - Revenue has received cogent tangible material having live link/nexus with the reasons to believe that the income has escaped assessment, the...

5. Reopening of assessment u/s 147 - details available in the books of account for balance sheet or profit or loss account cannot absolve the assessee from his disclosure...

6. Reopening of assessment u/s 147 - it is not permissible to adopt different standards while interpreting the words “reason to believe” vis-a-vis Section 143(1) and...

7. Power of reopening of assessment u/s 147 Explanation 1 r.w section 143(1) - reasons for the notice u/s 147 nowhere mentioned that the revenue came up with any other...

8. Re-assessment u/s 147 - AO was clinched with tangible information in the shape of information from Sales Tax Authorities which prima-facie suggested possible escapement...

9. 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...

10. Reassessment u/s 147 - original return filed was accepted without any scrutiny - the reasons so assigned would confirm that no tangible material was in possession of the...

11. Validity of reopening of assessment - original proceedings for assessment were by way of an intimation under Section 143(1)(a)/143(1) - We find no legal infirmity in the...

12. 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...

13. 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...

14. Validity of Reopening of assessment u/s 147 - while recording the reasons, the AO has considered the relevant facts like issue of stock in trade, the way in which the...

15. Reassessment u/s 147 - original assessment u/s 143(1) - material has been received from the Information Wing - assumption of jurisdiction in this case cannot be faulted,...