#Section 147
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Claim Allowed in Original Assessment Cannot be Amenable to Provisions of Section 147/148
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Enhancement by CIT(A) on an issue which were not part of reasons recorded for reopening the assessment are invalid
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Re-Opening of Assessment u/s 147 Merely Relying upon Investigation Report Not Justified in Law
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Reassessment based on Invalid Facts with no Application of Mind is Invalid
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Complemented Assessment cannot be reopened U/s. 147/148 on Borrowed Satisfaction
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Section 147/148 proceedings on mere investigation wing information was not valid
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Section 80P deduction can be claimed while filing return in response to Section 148
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Additions in reopened Assessment not valid if no addition on subject matter of reopening
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No section 36(1)(iii) disallowance unless Direct Nexus between Borrowed Funds & Capital Withdrawals
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Conditions Precedent for Reopening of Assessment beyond 4 Year- Section 147
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Basics of Income Escaping Assessment – Section 147 – Income Tax Act, 1961
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In absence of new facts reopening of already examined issue was invalid
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No reopening if no failure of assessee to disclose fully & truly all material facts necessary for assessment
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