Reopening of assessment u/s 147 - The requirement of section 147 ...

Assessment Reopening Needs Assessing Officer's Belief of Escaped Income u/s 147 of Income Tax Act.

April 29, 2022

Case Laws Income Tax AT

Reopening of assessment u/s 147 - The requirement of section 147 of the Act is the Assessing Officer has reason to believe that income chargeable to tax has escaped assessment. Assessing Officer’s reason to believe is sine-qua-non for reopening assessment. It is not the reason to believe of PCIT or any other authority which matters when it comes to the provisions of section 147 of the Act. - AT

View Source

← Previous Next →

Reopening of assessment u/s 147 - The requirement of section 147 ...

Assessment Reopening Needs Assessing Officer's Belief of Escaped Income u/s 147 of Income Tax Act.

April 29, 2022

Case Laws Income Tax AT

You may also like:

Formation of belief by the Assessing Officer that income has escaped assessment is the crux of the reopening provision. The reasons recorded must be based on tangible...

Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a...

Reopening of assessment u/s 147 - As examined the belief of the Assessing Officer to a limited extent to look into whether there was sufficient or any tangible materials...

Validity of reopening of assessment u/s 147 - Addition u/s 68 - The function of the assessing authority at this stage is to administer the statute and what is required...

Reopening of assessment u/s 147 - There was live link or direct nexus between the material which suggested the escapement of income and information on the basis of...

The High Court held that the Assessing Officer could not reopen the assessment u/s 147 as the basic precondition of having "reason to believe" that income had escaped...

Reopening of assessment u/s 147 - Disallowance u/s 14A - If at all he has considered, he has not even passed the assessment order by ignoring the provisions of law, i.e....

Reopening of assessment u/s 147 - Mere production of books of account and the details by the assessee are one aspect of the matter and even with reference to such books...

Reopening of assessment u/s 147 - The words ‘ reason to believe’ appearing in Section 147 cannot mean that the A.O should have finally ascertained the facts. Assessing...

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

The case pertains to the reopening of assessment u/s 147/148 of the Income Tax Act due to undisclosed cash deposits in the assessee's bank accounts. The key points are:...

Reopening of assessment u/s 147 - looking to the scope of section 147 as also sections 148 to 152 of the Act, even if scrutiny assessment has been undertaken, if...

Reopening of assessment u/s 147 - Once the Assessing Officer records the reasons that he has reason to believe that income has escaped assessment, it confers...

Reopening of assessment u/s 147 or u/s 153C - validity of proceedings - The High Court emphasized the need for the Assessing Officer to properly apply relevant...

Validity of Re-assessment under 147 where notice u/s 143(2) has been issued - if the Assessing Officer is of the view that materials available with him or discovered by...

Quick Updates: