#Section 147
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5,090 articlesIncome Tax

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Reopening of assessment on the basis of change of opinion is untenable
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Reopening of assessment without any new tangible material is unsustainable
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Gujarat HC quashed Section 148 notices for AY 2013-2014 & 2014-2015
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Gujarat HC set aside section 148 notices & 148A(d) orders in 257 cases
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Initiation of reassessment in spite of full & true disclosure is untenable
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Allahabad HC on Section 148 Notices issued after 01.04.2021 for AY 2013-14 to 2017-18
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Reopening of assessment without any new information is unjustified
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Notice issued without sufficient reasons to initiate reassessment is not sustainable
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Reopening of assessment despite full & true disclosure of material facts is unjustifed
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Mere ‘reason to believe’ not satisfy condition for reopening of assessment
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Reopening of assessment and imposition of penalty set aside as AO failed to satisfy HC direction
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If foundational allegation found to be false/non-existing, entire subsequent proceedings would collapse
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Information vs. Information suggesting escapement of income from tax
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