#Section 147
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Despite specific queries in scrutiny assessment, AO cannot be said to have formed any opinion if explicit opinion not recorded
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Clarificatory Note – Reg. provisions of section 147 r.w. Explanation 3 thereto, of I.T. Act, 1961
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Reassessment not permissible if reasons recorded are merely change of opinion
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Period of limitation for CIT order u/s 263 for issue, which is not the subject matter of reassessment
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If AO has examined the issue of loss arising out of fluctuation in foreign exchange, then reassessment cannot be initiated
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Reassessment proceedings u/s.147 read with 148 of the Act cannot be initiated merely based on the audit report
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Non-issue of s. 143(2) notice renders s. 147 assessment order invalid
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Proviso to Section 14A bars reassessment but not original assessment on the basis of the retrospective amendment
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Assessment beyond a period of four years can not be re-opened where there is full and true disclosure of all material facts by assessee
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Reopening without proper application of Mind by Assessing officer is invalid
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Section 147 of Income-tax Act – Unless twin conditions of proviso to section 147 are satisfied, notice issued under section 148 is without jurisdiction and on that ground alone notice is liable to be quashed
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Reassessment beyond four years on the basis of retrospective amendment not justified
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Reopening under section 147 on mechanical basis void even where s. 143(3) assessment not made
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