Reopening of assessment u/s 147 - power to review v/s power to ...

Court Clarifies Limits on Reopening Tax Assessments u/s 147: Distinguishes Between Review and Reassessment Powers.

October 9, 2021

Case Laws Income Tax HC

Reopening of assessment u/s 147 - power to review v/s power to reassess - Only material relied upon by the assessing officer, in this case, is the material supplied by the assessees themselves along with their return - A mere change in opinion cannot be a reason to reopen. This decision holds that there is a conceptual difference between power to review and power to reassess and that the assessing officer has no power to simply review - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - power to review v/s power to ...

Court Clarifies Limits on Reopening Tax Assessments u/s 147: Distinguishes Between Review and Reassessment Powers.

October 9, 2021

Case Laws Income Tax HC

You may also like:

Absence of incriminating material during search precludes additions in completed assessments, as per Supreme Court's ruling in Principal Commissioner of Income-tax,...

Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening...

Reopening of assessment u/s 147 - Reopening based on audit objections - reasons to believe - High Court observed that, reopening an assessment beyond four years requires...

The High Court held that the Assessing Officer cannot reopen the assessment u/s 147 merely based on a change of opinion. The assessee had fully and truly disclosed all...

Section 147 allows reopening of assessments in exceptional cases where the Assessing Officer has reason to believe income has escaped assessment. Concluded assessments...

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...

Reopening of assessment u/s 147 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion...

Reopening of assessment u/s 147 - It is sufficient if any one of the conditions stipulated in Proviso clause to Section 147 is satisfied for reopening of assessment. -...

The High Court addressed the issue of reopening assessment u/s 147 of the Income Tax Act. The case involved the alleged absence of a "reason to believe" and a "live...

Reopening of assessment u/s 147 - reopening after expiry of four years - Original assessment have been passed under section 143(3) on Dated 14.12.2011 and A.O. recorded...

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...

Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information...

The Assessing Officer (AO) reopened the assessment solely based on the information from a survey conducted by the Sales Tax Department, without independently examining...

Reopening of assessment u/s 147 - This being the scope of Section 147 for reopening of assessment, this Court do not find any acceptable reason for the purpose of...

Reopening of assessment u/s 147 - reply to the audit objections - in fact AO applied his mind to the audit party objection and formed a clear opinion that there is no...

Quick Updates: