#Section 147
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5,090 articlesIncome Tax

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Extension of time for completion of assessments and reassessments
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Budget 2012 – Reopening time limit Increased to 16 Years for income in relation to asset located outside India
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Reopening Notice u/s 147 issued within Limitation Period but served after Limitation Period is valid
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Section 147 applies both to section 143(1) as well as section 143(3) – No reopening u/s 147 in absence of ‘new material’
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For exercise of power U/s. 263, it is mandatory that order passed by AO should be erroneous and prejudicial to interest of Revenue
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Delay in notice U/s. 143(2) Renders Assessment Void – HC
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Retrospective amendment no basis to reopen beyond 4 years – HC Disapproves AO’s Practice to Delay Passing Objection Orders
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Sanction of CIT instead of JCIT renders reopening u/s. 147 of Income Tax Act invalid
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Whether assessment can be re-opened beyond four years when all primary facts for making the claim were disclosed to the AO
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Mere opinion of the Audit Party cannot form the basis for the Assessing Officer to reopen the closed assessment
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Full and true disclosures must mean what the statute says and requires specific disclosure of each fact – Bombay HC
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Reopening under section 147 For Lapse Of AO Invalid – Delhi High Court
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Power to reopen an assessment cannot be exercised to reopen what formed subject matter of an appeal to Commissioner (Appeals)
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