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High Court states that if the Assessing Officer had no jurisdiction to initiate re- assessment proceeding, the mere fact that subsequent orders have been passed would not render the challenge to jurisdiction infructuous. If the very basis for re- opening assessment does not survive, orders on such re-opening would not survive too. Hence, considering the matter in its entirety HC are of the view that the impugned notice under Section 148 of the Act issued by AO cannot be sustained.
ITAT Kolkata ruling on Amrabathi Investra (P) Ltd. Vs ITO case. Assessment reopened u/s 147. Read full judgment details and outcome.
Each aspect of Section 147 has been a subject matter of careful scrutiny by the court of law. One such main issue is with respect to the validity of the assumption of jurisdiction by the AO to reopen the assessment beyond four years, merely by making a Bald Assertion in the reasons as to the failure of the Assessee to disclose fully and truly all the material facts. The author has made an analysis veracity of such practice with the help of available judicial pronouncements
Whether AO is correct in rejecting the claim of assessee regarding the deduction u/s 54F, which was made first time during Reassessment Proceedings?
AO was not justified in reopening of assessment after four years as on an independent application of mind and on thorough consideration of material aspects and legal position,there was no failure on the part of assessee.
DCIT Vs Coal India Ltd (ITAT Kolkata) Section 148 of the Act does not authorize the AO to issue fresh notice when proceedings on a previous notice u/s. 148 of the Act are still pending and have not been finally disposed of. Similar view was taken by the Hon’ble Allahabad High Court in Commercial Art […]
ITAT states that the assessee has disclosed the sale of shares in its books of account. Once the sale is declared as income by the assessee, the question of treating the same amount as a cash credit u/s 68 of the Act results in double addition. Thus, the addition is also bad on merits. Hence, the appeal of the assessee is allowed.
International Flavours and Fragrances India Private Limited Vs DCIT (Madras High Court) The issue under consideration is whether the notice issued u/s 147 for re-opening the assessment is justified in law? Petitioner is engaged in manufacture of flavour essences, mixed seasoning powders (dry mix) and formulated perfumery compounds etc. The petitioner started a new manufacturing […]
Reassessment was justified by the income tax department against former Indian Cricket Team Captain Krishnamachari Srikanth and non compete fee of Rs. 7.50 crores was exempt from tax being capital receipt;
The issue under consideration is whether the Assessing officer is correct in rejecting the objections filed by the petitioner against the reasons for reopening the assessment without passing speaking order?
