Reopening of assessment u/s 147 - Change of opinion - Once the ...

Reopening Tax Assessment u/s 147 Not Justified if Based Solely on Change of Opinion After Full Disclosure.

October 16, 2023

Case Laws Income Tax HC

Reopening of assessment u/s 147 - Change of opinion - Once the assessee makes a true and full disclosure of the primary facts at the time of the original assessment and which could have been discovered with due diligence by the Income Tax Officer, drawing an inference which appears subsequently to be alone, is a mere change of opinion - HC

View Source

← Previous Next →

Reopening of assessment u/s 147 - Change of opinion - Once the ...

Reopening Tax Assessment u/s 147 Not Justified if Based Solely on Change of Opinion After Full Disclosure.

October 16, 2023

Case Laws Income Tax HC

You may also like:

Reopening of assessment u/s 147 - The duty is cast upon the assessee to make true and full disclosure of the facts at the time of original assessment. The duty of the...

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...

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...

The assessment order was challenged on the grounds of validity of reopening after four years, based on a change of opinion and borrowed satisfaction. The assessee...

Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based...

Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but...

Reopening of assessment u/s 147 - reply to the audit objections - in fact AO applied his mind to the audit party objection and formed a clear opinion that there is no...

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

Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not...

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...

Reopening of assessment u/s 147 - reason to believe - commencement date / year for deduction u/s 80IA - Eligible from 1995 or 2000 - scope of change of opinion - We...

Reopening of assessment u/s 147 - sufficiency or inadequacy of reasons - There is no whisper in the impugned order as regards any failure on the part of petitioner to...

Reopening of assessment u/s 147 - Change of opinion - As has always been observed, notice under Section 147 is not to be casually invoked to suit the convenience of the...

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...

Reopening of assessment u/s 147 - Addition u/s 14A read with Rule 8D. "Reason to believe" in Section 147 means cause or justification for the competent authority to...

Quick Updates: