Home Highlights June 2012 Year 2012 This

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1. Validity of Re-assessment under 147 where notice u/s 143(2) has been issued - if the Assessing Officer is of the view that materials available with him or discovered by...

2. Reopening of assessment u/s 147 - Reasons for belief that income has escaped assessment - Merely having a reason to believe that income had escaped assessment, is not...

3. Issue of notice versus service of notice - Income escaping assessment - validity of notice u/s 147 - there has been proper issue of notice within the limitation period...

4. Reopening of assessment u/s 147 - There was live link or direct nexus between the material which suggested the escapement of income and information on the basis of...

5. Reopening of assessment u/s 147 - reasons to believe - no income under the head income from House Property has been offered by the assessee during the year under...

6. Reopening of assessment u/s 147 - Once the Assessing Officer records the reasons that he has reason to believe that income has escaped assessment, it confers...

7. Reason to believe for income escaping assessment under section 147 - The reasons were such which would impel an ordinary person of reasonable prudence to hold that the...

8. Validity of reopening of assessment u/s 147 - Addition u/s 68 - The function of the assessing authority at this stage is to administer the statute and what is required...

9. Reopening of assessment u/s 147 - The words ‘ reason to believe’ appearing in Section 147 cannot mean that the A.O should have finally ascertained the facts. Assessing...

10. Assessment to be framed u/s 153C OR u/s 147/148 - Validity of the reassessment proceedings - Initiation of action u/s 153C would arise only if the seized material are...

11. Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a...

12. Reopening of assessment u/s 147 - The tribunal has not considered the provisions of Explanation 2(b) to Section 153 of the Act, by which the Assessing Authority is...

13. Reopening of assessment v/s assessment u/s 153C - The Appellate Tribunal acknowledged the argument presented by the appellant and emphasized the importance of applying...

14. Assessment u/s 153A or u/s 147/148 - any incriminating information of any undisclosed income of the person not searched which was found during the course of a search...

15. Reopening of assessment u/s 147 - a plain reading of clause (ca) of Explanation 2 of Section 147 makes it clear that it cannot be gainsaid that Section 133C survey...