Reopening of assessment u/s 147 - Reasons for belief that income ...

Reopening Tax Assessments: Section 147 Requires Full Disclosure Failure for Beyond Four-Year Reassessment.

July 5, 2022

Case Laws Income Tax AT

Reopening of assessment u/s 147 - Reasons for belief that income has escaped assessment - Merely having a reason to believe that income had escaped assessment, is not sufficient to reopen assessments beyond the four year period, as explained above. The escapement of income from assessment must also be occasioned by the failure on the part of the assessee to disclose material facts, fully and truly. - AT

View Source

← Previous Next →

Reopening of assessment u/s 147 - Reasons for belief that income ...

Reopening Tax Assessments: Section 147 Requires Full Disclosure Failure for Beyond Four-Year Reassessment.

July 5, 2022

Case Laws Income Tax AT

You may also like:

The Appellate Tribunal examined the reopening of assessment after four years and the addition u/s 68 of the Income Tax Act. It held that the original assessment was...

The ITAT allowed the assessee's appeal against the reopening of assessment u/s 147 beyond the four-year period. The Assessing Officer failed to record a finding that the...

Reopening of assessment notice beyond four-year period quashed. Assessee submitted complete details for section 80IA deduction claim with return. No failure to disclose...

Reopening of assessment after four years is invalid as the recorded reasons do not mention any failure by the assessee to fully and truly disclose all material facts...

Reopening of assessment u/s 147 was based on reasons to believe the difference between total cash sales and cash sales reflected in books. Held: Reopening was made only...

Mere assertion of "failure to disclose fully and truly all material facts" does not confer jurisdiction for reopening assessment beyond four years. AO must demonstrate...

Reopening of assessment u/s 147 - Reopening based on audit objections - reasons to believe - High Court observed that, reopening an assessment beyond four years requires...

Reopening of assessment u/s 147 - reopening as based on audit objection - notice beyond four years - since four years had expired from the end of the relevant assessment...

Reopening of assessment - reason to believe - onus to prove - The High court noted that reassessment beyond four years from the end of the relevant assessment year is...

Reopening of assessment u/s 147 - deemed dividend addition u/s 2(22)(e) - gap of more than four years - when the amount received by the two concerns from the loan giver...

Reopening of assessment after expiry of four years due to deemed dividend u/s 2(22)(e) was found invalid. The Assessing Officer (AO) failed to establish that the...

HC quashed notice for reopening assessment under s.147 due to AO's failure to specify which material facts were not fully disclosed by petitioner. Court emphasized that...

HC quashed reassessment notices and order finding them invalid under Section 147 of Income Tax Act. Notices issued after four years were without fresh material...

The HC held that the reopening of assessment beyond four years was without jurisdiction as the reasons did not disclose any material facts that the assessee failed to...

Reopening of assessment u/s 147 - When the assessment is sought to be reopened after the expiry of period of four years from the end of the relevant year, the proviso to...

Quick Updates: