#Reassessment
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1,154 articlesIncome Tax

Income Tax
Reopening based on mere Shah Commission Report not Valid if no Application of Mind by AO
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‘Reasons to Believe’ is Different from ‘Reasons to Suspect’: SC
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Section 147 proceedings not identical to section 143(2) proceedings
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Section 147 Reopening invalid if made without following mandate of Section 147,148 & 151
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No reassessment if AO fails to bring new material on record
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Reassessment based on Incorrect/Non-Existing reasons is Illegal & Bad in Law
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Section 143(2) Notice on very same day of Return Filing makes Reassessment Invalid
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Reassessment invalid if section 143(2) notice was issued on very same day of filing ITR
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Recording of reasons after due application of mind is sine qua non for valid section 148 notice
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Reason to believe not valid if after 01.04.1989, if it lacks application of Mind & Material
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Reasonable belief sufficient for Section 147 notice; Final conclusion not required
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Reassessment upheld on the ground of established business connection
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AO can initiate reassessment if excess deduction was allowed based on wrong information supplied to it
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