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Section 147 can be invoked only if AO has reason to believe that taxable income has escaped assessment
Case Law Details
- Case Name
- Oriental Insurance Company Vs CIT (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
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Brief of the case
In case of Oriental Insurance Company vs. CIT, Delhi High Court held that AO could not assume jurisdiction to reopen assessment u/s 147, until his reasons of belief have a ‘direct nexus’ and a ‘live link’ with the opinion formed by him, that Taxable Income of Assessee has escaped assessment.
Facts of the case
The Appellant Company is a subsidiary of General Insurance Corporation of India and is engaged in the business of General Insurance comprising of Fire, Marine and Miscellaneous Insurance Business.It invests its policy holder’s funds as per the statutory guidel...
