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 - Proof of new ...

Income Tax

October 29, 2021

Validity of reopening of assessment u/s 147 - Proof of new material to justify the re-opening of the assessment - change of opinion - there was conscious application of mind by the AO to the said materials. Therefore, the inevitable conclusion as far as the present case is concerned is that the ‘reason to believe’ of Opposite Party No.1 that income for the AY in question had escaped assessment is based on a mere ‘change of opinion’ - HC

View Source

 


 

You may also like:

  1. 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...

  2. Reopening of assessment - Applicability of section 145A - valuation of closing stock - Not open for AO to reexamine the entire issue which would be merely on the change of opinion.

  3. Validity of Reopening of assessment u/s 147 - The Tribunal emphasized the principle that for reassessment under Section 147 of the Income Tax Act, the onus is on the...

  4. Reopening of assessment u/s 147 - double deduction u/s 80IB - In the reasons for re-opening, there is not even a whisper as to what was not disclosed. In our view, this...

  5. Reopening of assessment u/s 147 - The reasons recorded for reopening the assessment contain ample proof in itself to show that there was no new material in the...

  6. Reopening of assessment u/s 147 - It is clear that the primary facts necessary for assessment were also disclosed. It is settled law that the Assessing Officer is not...

  7. Reopening of assessment u/s 147 - When the primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not entitled to a change of...

  8. Reopening of assessment u/s 147 - change of opinion - The impugned notice and the consequent action is legally unsustainable as the Revenue fails to satisfy the twin...

  9. Reopening of assessment u/s 147 - Change of opinion - We are of a strong conviction that in the garb of reopening the case of the assessee he had on the basis of the...

  10. Reopening of assessment u/s 147 - Reasons to believe - The ITAT thoroughly examined the reasons recorded by the AO for re-opening the assessment and found that there was...

 

Quick Updates:Latest Updates