Home Highlights March 2017 Year 2017 This

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1. Reopening of assessment u/s 147 after 4 years - Validity of Sanction for issue of notice u/s 151 - respectfully following the aforesaid decision provisions of section...

2. Reopening of assessment - condition precedent necessary under Section 151(1) not complied - recording of satisfaction - issue of notice after 4 years - the impugned...

3. Reopening of assessment u/s 147 - sanction required u/s 151 has not been validly obtained - even while conveying the approval for re-opening, Addl.CIT has displayed...

4. Validity of Assessment u/s 153A - non-generation of DIN - approval u/s. 153D of the Act is akin to the approval u/s. 151 of the Act, wherein, we find sanction/approval...

5. Reopening of assessment u/s 147 - reopening as based on audit objection - notice beyond four years - since four years had expired from the end of the relevant assessment...

6. Reopening of assessment u/s 147 - absence of valid approval to be obtained u/s 151 - The Appellate Tribunal noted that the approval obtained from the Additional...

7. Validity of reopening of assessment - validity of approval from a superior authority - when 151(2) of the Act mandates that sanction to be taken for issuance of notice...

8. Reopening of assessment u/s 147 - Whether no proper sanction/approval on the date of issuance of notice under Section 148 is concerned, provision under Section 151? - In...

9. Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was...

10. Validity of Reopening of assessment u/s 147 - AO should not have issued notice without satisfying the condition precedent as laid down in clause (b) of section 149(1) of...

11. 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...

12. Validity of reopening of assessment - necessity to have a valid approval under section 151 - PCIT while according to approval for reopening the assessment has either not...

13. Validity of reopening of assessment u/s 147 - by the time, assessment order for the assessment year 2004-05 was passed on 31.12.2010, six year period for reopening of...

14. Reopening of assessment u/s 147 - There is no indication of any application of mind by the authority. Moreover, the approval under Section 151 of the Act had to be...

15. Validity of reopening of assessment u/s 147 - appropriate authority - if Joint Commissioner approves the proceedings/ proposal sent by the Assessing Officer to be a fit...