#Section 147
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Reopening based on Change of opinion is invalid; HC dismisses Appeal in Airtel case
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S. 147 / 148 Non disposal of objection raised makes reassessment invalid
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Provision of law overlooked during original assessment – Reassessment Notice beyond four years is not valid
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Non-issue of notice u/s. 143(2) after filing of return makes assessment u/s. 143(3) /147 bad in law
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Assessment U/s. 147 not become invalid for satisfaction of Reasons recorded by both CIT & JCIT
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Reopening of assessment beyond a period of 4 years to make fishing inquiries not justified
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Reopening of assessment not permitted if no Failure of Assessee to disclose material facts
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May be Right Thing done in Wrong Manner
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Reopening not permissible on the ground of expense which was not claimed by Assessee
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Accommodation entry: Reassessment based on mere inquiry in case of 3rd party not justified
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Initiation of reassessment during pendency of Sec. 143(2) proceedings is invalid
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Reassessment not valid if time to issue notice U/s. 143(2) not expired
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AO cannot have disregard finding directions of DRP and pass final assessment order
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