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 November 2021 Year 2021 This

Validity of re-assessment proceedings initiated u/s.148 - If the ...

Income Tax

November 19, 2021

Validity of re-assessment proceedings initiated u/s.148 - If the reasons recorded are silent or there is no reference of any material, then other extraneous material referred subsequently cannot justify acquiring of jurisdiction for reopening u/s 147. Any annexure or report discussed in the assessment order which is not part of the reasons recorded cannot be construed as material forming belief u/s.147. - The reasons recorded itself goes to show that it is purely based on borrowed satisfaction and without application of mind - AT

View Source

 


 

You may also like:

  1. Validity of reopening of assessment - It is well settled Law that validity of the reassessment proceedings is to be judged with reference to the reasons recorded for...

  2. Reopening of assessment u/s 147 - It is well established that the reasons recorded by the AO cannot be further be substituted or added or deleted - We are of the view...

  3. Validity of Reopening of assessment u/s 147 - requirement of recording of “reasons to believe” - validity of jurisdiction assumed by the AO for reopening the case of the...

  4. Assessment u/s 153C - satisfaction on the basis of the borrowed information - It is true that the supreme Court has made the said observations while considering the...

  5. Reopening of assessment u/s 147 - reasons to believe - It is settled law that the reasons for reopening an assessment can be tested and examined only on the basis of the...

  6. Reopening of assessment u/s 147 - Addition u/s 68 - unexplained share premium - While recording the reasons for reopening the assessment, the AO did not even care to...

  7. 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,...

  8. Penalty u/s 271(1)(c) - Reopening of assessment u/s 147 - addition of unexplained investment in property u/s 69 - firstly the AO who records the reasons and issues a...

  9. Notice u/s 148 - AO has not recorded any reasons for re-assessment proceedings and merely acted on the borrowed satisfaction recorded by another AO without jurisdiction...

  10. 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...

  11. Reopening of assessment u/s 147 v/s assessment u/s 153C - proceedings initiated u/s 132 - The correct course of reassessment is under section 153C not under section 147...

  12. Reopening of assessment u/s 147 - Reasons to believe - The court examined the reasons recorded for re-assessment provided to the petitioner and compared them with the...

  13. Reopening of assessment u/s 147 - reason recorded by the AO or the issuance of notice u/s 148 does not give any indication of obtaining sanction from the ACIT/JCIT...

  14. Validity of the reopening of proceedings under section 147 - Assessee contended that, assessment was framed on the basis of mere internal office note, without recording...

  15. Initiation of re-assessment proceedings - Reasons to believe - AO initiated re-assessment proceedings just to verify the deposits and withdrawals from the bank account...

 

Quick Updates:Latest Updates