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 May 2022 Year 2022 This

Reopening of assessment u/s 147 - Keeping in view the aforesaid ...


Court Rules Reassessment u/s 147 Invalid Due to Change of Opinion on 'A Barracks' Rent Issue.

May 7, 2022

Case Laws     Income Tax     HC

Reopening of assessment u/s 147 - Keeping in view the aforesaid facts, this Court is of the view that the issue of rent of ‘A Barracks’ was within the knowledge of the Assessing Officer when he had passed the original assessment order as well as the subsequent order under Section 154 of the Act. Consequently, this Court is in agreement with the opinion of the ITAT that reassessment proceeding in the present case was based on a change of opinion and the same, therefore, cannot be sustained. - HC

View Source

 


 

You may also like:

  1. 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...

  2. Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147...

  3. The Calcutta High Court examined the validity of reassessment proceedings u/s 147 based on change of opinion regarding the assessee's liability u/s 115JB. The Court...

  4. ITAT dismissed Revenue's appeal against CIT(A)'s order invalidating reassessment proceedings under s.147. AO had previously examined share premium issue during original...

  5. The High Court quashed the reassessment proceedings initiated by the Assessing Officer u/s 148 of the Income Tax Act, holding it to be a case of "change of opinion" and...

  6. The ITAT Nagpur considered the validity of reassessment proceedings u/s 147. The AO issued notice beyond four years alleging capital gain on "Sale of Vehicles" escaped...

  7. Reopening of assessment u/s 147 - The High Court dismissed the appeal filed by the revenue, affirming the decision of the Income Tax Appellate Tribunal (ITAT) that...

  8. Reopening of assessment u/s 147 - Reasons to belive - change of opinion - there was no new material which had come to the notice of the Assessing Officer and the entire...

  9. Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of...

  10. Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for...

  11. The High Court held that the reassessment order dated 12.05.2023 and subsequent proceedings were invalid as they were beyond the statutory limitation period prescribed...

  12. The High Court held that the reassessment proceedings initiated by the Revenue were invalid due to the absence of any failure on the part of the assessee to disclose...

  13. The High Court held that the jurisdictional facts necessary to invoke Section 147 for reassessment were absent. The reassessment was initiated after the four-year...

  14. Reopening of assessment u/s 147 - Change of opinion - the threshold bar for initiation of the reassessment proceedings is satisfied. This Court must conclude, at this...

  15. Validity of reopening an assessment u/s 147 of the Income Tax Act, the distinction between "change of opinion" and "reasons to believe," and the classification of income...

 

Quick Updates:Latest Updates