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Reopening of assessment was justified in case of EDPL as there were sufficient ‘reasons to believe’ that income had escaped assessment and the bar to reopening of proceedings after expiry of four years from the date of final assessment order, under the proviso, did not apply in assessee’s case and there was no requirement to issue two separate notices in the name of amalgamated company (i) as successor-in-interest of the amalgamating company and (ii) in its individual capacity as EDIPL had ceased to exist as a separate entity.
Price Waterhouse & Co. Vs DCIT (ITAT Kolkata) Conclusion: Since the addition on basis for which AO reopened assessment had already been disclosed by assessee in the return of income filed by him u/s 139(1), AO having not carried out the scrutiny assessment within the prescribed statutory limit, could not be given another innings for […]
The issue under consideration is whether the re-opening of assessment is justified if it is based on the similar issues and evidences which have been already considered in original assessment?
It was submitted that therefore, the first proviso to section 148 of the Act would be attracted and the assumption of jurisdiction on the part of the Assessing Officer under section 147 of the Act is invalid.
CBDT has issued instruction dated 12th February 2018 to conduct assessment proceedings in scrutiny cases electronically, saying that except for search-related assessments, proceedings in other pending scrutiny assessment cases shall be conducted only through the E-proceeding functionality in ITBA/e-filing.
Many times in Reassessment proceedings very little importance & attention is paid to the timing of issue of notice under section 143(2). Section 143 of Income Tax Act is about Assessment, subsection 2 of section 143 talks about issue of notice in cases where return of income has been filed within the time limits specified […]
Section 148 stands for reassessment or income escaping assessment. Nowadays income tax department is scrutinizing more returns under Section 148 of the Income Tax Act. So we are here to discuss about section 148 of the Income Tax Act, 1961. Article explains Time limit for issuance of notice u/s 148, Issuance of show cause notice […]
In such cases, assessments can be reopened only if an income assessable to tax has escaped on account of failure of the assessee to disclose all the material facts fully and truly. In other words, the AO has to demonstrate that income of the assessee has escaped assessment on account of its failure to disclose all material facts of the assessments in its income fully and truly.
In the given case, the Petitioner who is a regular income tax assessee filed her return of income for the AY 2011-12. The Assessing Officer issued under section 133(6) of the Act, called for certain information from the assessee.
Approval given by approving authority for reopening of assessment u/s 147 of the Income Tax Act, 1961 was without due application of mind and in mechanical manner – reassessment should be quashed.
