#Section 147
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Assessment of earlier year cannot be reopened on the basis of persuasive finding in subsequent years
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Payment of Cash Salary Exceeding Rs. 20000 not allowable U/s. 40A(3)
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S. 147 Supply of recorded reasons after passing reassessment order renders the reopening void
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Initiation of reassessment proceedings on basis of assessment for subsequent assessment year
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For reopening there must be ‘tangible material, bearing a ‘live link with formation of belief’
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When there is detailed scrutiny with regard to an issue, no re-opening for mere change of opinion
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Reassessment reasons to believe should be clear & not ambiguous
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Furnishing of additional information by AO is not expression of opinion
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Even Section 143(1) Assessment Cannot Be Reopened u/s 147 In Absence Of New Material
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HC Cannot set aside reopening of assessment without giving the reason
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Only Joint Commissioner or Additional Commissioner can sanction issue of Reassessment Notice
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Reassessment not valid if Assessee fully & truly disclosed all material facts
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Reassessment valid if income is inflated to claim higher deduction u/s. 80IA
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