Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights October 2021 Year 2021 This

Validity of reopening of assessment u/s 147 - validity of reason ...


High Court Rules Reopening Assessment Invalid Due to Change of Opinion u/s 147.

October 13, 2021

Case Laws     Income Tax     HC

Validity of reopening of assessment u/s 147 - validity of reason to believe - during the scrutiny assessment, the case was discussed with the assessee on four dates, prior to which, a questionare containing as many as 13 questions were put to the assessee with direction to file relevant documents and on scrutiny of those documents, the Assessing Officer called for further particulars which had also been furnished by the assessee - the reopening of the assessment is a clear case of change of opinion - HC

View Source

 


 

You may also like:

  1. Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not...

  2. 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...

  3. 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...

  4. The case pertains to the reopening of assessment u/s 147 of the Income Tax Act. The key points are: The department had already raised queries regarding the accumulation...

  5. Reopening of assessment u/s 147 was invalid as Assessing Officer (AO) failed to record that assessee did not disclose fully and truly all material facts necessary for...

  6. Reopening of assessment u/s 147 - reason to believe - commencement date / year for deduction u/s 80IA - Eligible from 1995 or 2000 - scope of change of opinion - We...

  7. Reopening of assessment u/s 147 - Reason to believe - change of opinion - the reassessment is being resorted to only on account of ‘change of opinion’ of the Assessment...

  8. Reopening of Assessment u/s 147 - change of opinion - By change of opinion holding that reduction towards reversal on account of cancellation and price revision and...

  9. Reopening of assessment u/s 147 - change of opinion - when the primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not...

  10. Reopening of assessment under s.147 challenged on grounds of invalid notice under s.143(2) and "change of opinion." ITAT held notice under s.143(2) was valid as return...

  11. Reopening of assessment u/s 147 - Reason to believe - change of opinion - The reason we say that there is a change of opinion is because once a query has been raised...

  12. Reopening of assessment u/s 147 was challenged. The Assessing Officer (AO) had disallowed 20% of total sundry creditors in the regular assessment u/s 143(3). The AO...

  13. Reopening of assessment u/s 147 was challenged on the ground of mere change of opinion. The assessee had filed return claiming deduction u/s 80IC and furnished all...

  14. Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based...

  15. Reopening of assessment u/s 147 - sufficiency or inadequacy of reasons - There is no whisper in the impugned order as regards any failure on the part of petitioner to...

 

Quick Updates:Latest Updates