#Section 147
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Merely applicability of sec 50C will not prove escapement of Income
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Reopening on the basis of vague / uncertain information on Accommodation Entry not valid
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Income Tax
Despite Sanction Reopening Void If Satisfaction is Recorded in a casual or routine manner
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Reassessment order cannot be challenged in Writ – SC
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Income Tax
Subsequent reversal of the legal position by judgment of Supreme Court does not authorize the department to reopen the assessment
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Income Tax
Reassessment on the basis of subsequent decision cannot be said to be a mere change of opinion
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Income Tax
No addition during reassessment of a particular expense which has been duly examined by the AO during Original Assessment proceedings
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Reassessment not warranted on same existing set of facts, when a return and those facts already scrutinized
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Mere information regarding income escapement can be considered valid for the purpose of sec. 147
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Reopening not valid if reasons silent on quantum of escaped tax
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Reassessment Notice for mere change of opinion is impermissible in law
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Reassessment initiated on the basis of materials which were available during original assessment not valid
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Income Tax
Initiation of Reassessment before expiry of time limit for scrutiny assessment is valid
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Income Tax
