Reassessment u/s 147 - the suggestion of DDIT(Inv.) does not ...

Reassessment Under Sec 147 Invalid: Lack of Independent Judgment and Nexus in Sec 148 Notice.

July 27, 2019

Case Laws Income Tax AT

Reassessment u/s 147 - the suggestion of DDIT(Inv.) does not confer power to assume jurisdiction upon the AO to initiate reassessment proceedings - notice u/s 148 was issued without any application of mind and examination of the so called material and information received from the investigation wing to establish any nexus, even prima facie, with such information, by way of borrowed satisfaction - not sustainable

View Source

← Previous Next →

Reassessment u/s 147 - the suggestion of DDIT(Inv.) does not ...

Reassessment Under Sec 147 Invalid: Lack of Independent Judgment and Nexus in Sec 148 Notice.

July 27, 2019

Case Laws Income Tax AT

You may also like:

ITAT invalidated reassessment proceedings due to jurisdictional defects in notice issuance under s.148. ITO Ward 3(2), Bulandsahar transferred assessee's records to ITO...

Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint...

Reassessment u/s 147 - fictitious F&O loss by manipulative client code modification - return was originally processed u/s 143(1) and notice u/s 148 was issued within...

Reopening of assessment u/s 147 was invalid due to lack of valid sanction as required u/s 151. The competent authority must independently apply its mind based on...

Reopening of assessment u/s 147 - Initiation of reassessment proceedings, u/s.148 of the Act and issued notice to the assessee was based on valid reason on the strength...

The ITAT Delhi held that the reopening of assessment u/s 147 was invalid as the JCIT granted approval mechanically without proper application of mind. The JCIT's...

The court held that the Joint Assessing Officer (JAO) lacked jurisdiction to issue notices u/s 148 of the Income Tax Act for reassessment, as per Section 151A read with...

The ITAT held that reopening assessment against a deceased person, a non-existing company converted into LLP, is invalid. The company's status as "dissolved" on MCA data...

The High Court held that for a valid reassessment notice u/s 148 of the Income Tax Act, the Revenue must comply with Section 151A, which mandates the issuance of such...

Reassessment proceedings were held invalid due to lack of proper jurisdiction by the Assistant Commissioner of Income Tax while issuing the notice u/s 148. The...

HC determined reassessment proceedings initiated under s.147/148 were invalid when based on materials discovered during search operation under s.132. Where incriminating...

The High Court ruled that the Joint Assistant Commissioner (JAO) lacked jurisdiction to issue notices u/s 148 for reassessment of income escaping assessment. The notices...

Reopening of assessment u/s 147 - Time limit for notice - there is no document made available to prove that the notice under section 148 dated 31.03.2018 was sent for...

Reopening of assessment u/s 147 - unexplained cash payment - Two notices issued u/s 148 - it is a case where pending conclusion of the first reassessment proceedings,...

Reassessment u/s. 147 - non availability of file containing reasons to believe - there is no material brought to our notice that reasons were recorded before issue of...

Quick Updates: