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ITAT Hyderabad Quashes Reopening: No Second Bite on Gift Addition – Change of Opinion Not Allowed
Case Law Details
- Case Name
- Daya Shanker Tiwari Vs ITO (ITAT Hyderabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-2018
- Courts
- All ITAT, ITAT Hyderabad
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Daya Shanker Tiwari Vs ITO (ITAT Hyderabad)
No second bite- Tribunal blocks AO’s attempt to retax gift-Same Story, Same Facts- AO’s revisit of same facts held impermissible – Change of opinion cannot justify Reopening
Original assessment was been completed u/s 143(3) determining the total income of Assessee at Rs.16,91,705 by making addition of Rs.5 lakhs u/s 69A as explained money towards gift received from Sri Pradeep Tiwari (PT). Subsequently, it was reopened u/s 147 for escapement of on account of under- assessment of gift to the extent of Rs.6 lakhs received from S...
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