#Reassessment
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1,177 articlesIncome Tax

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Reopening not permissible beyond 4 years where AO failed to consider material produced before him
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Reassessment u/s 148 quashed, on issue of notice without valid jurisdiction
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No new material besides full and true disclosure, reassessment u/s 148 is not justified
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Enquiry Proceedings u/s 133(6) – Whether more Grisly than Scrutiny
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S. 147 Reopening based on material placed before DRP considering the same as new material
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Reasons for initiating assessment u/s 147 should be recorded prior to issuance of notice u/s 148
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Reopening U/s 147 – `Incessant Trip to Litigation’
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Section 147: Power of Review V/s Power to Re Assess
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If AO not conducted proper inquiry, the obligation to do so is on CIT(A) & ITAT
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Merely Approval without application of mind not sufficient and renders reopening void
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Reopening on mere ground of Cash Deposit in Bank Account not Valid
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For invoking reassessment proceedings, reasons has to be recorded & not conclusions
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S. 148 Approval for issue of notice for re-assessment
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