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Provisions of section 147/148 even otherwise are for the benefit of the Revenue and not for the benefit of the assessee. If there was any mistake on the part of the assessee in filing his return of income, which was duly accepted by the Assessing Officer under section 143(1), the filing of appeal before the ld. CIT(Appeals) was not the proper remedy to correct the same.
Notice issued under section 147 of the Act in respect of an entity which ceases to exist by virtue of amalgamation order under section 394 of Companies Act, would be illegal and unsustainable.
he factum of issuance of notice within time is to be proved on query by the authority whose jurisdiction is challenged for want of The aggrieved party cannot be asked to lead negative evidence in support of its claim.
It is hence proposed to amend the provisions of sub-section (5) of section 139 to provide that the time for furnishing of revised return shall be available upto the end of the relevant assessment year or before the completion of assessment, whichever is earlier.
(a) Did the Tribunal fall into error in holding that the Commissioner of Income Tax (CIT) did not in fact record satisfaction under Section 151 of the Income Tax Act, 1961 for issuing notice under Section 147, in the circumstances of the case?
Bombay HC held that supplying of reasons for reopening assessment is a jurisdictional requirement and non-supplying of same when assessee specifically asked for same would made reassessment notice bad in law.
In Hitachi Home & Life Solutions (I) Ltd. vs. ACIT [ITA Nos. 3045/Ahd/2013 & 104/Ahd/2014, decided on 17.01.2017], briefly, the assessee being a company manufacturing/trading in air conditioners filed return of income on 20.12.2006 stating total income of Rs.15,62,01,340/-. It however returned nil income after adjusting carry forward losses.
Notice as prescribed U/s. 143(2) was not properly served on assessee, ITAT Kolkata, held, that assessment made U/s. 144 of the Act was not valid & it was quashed.
Mere increase in turnover, because of use of digital means of payment or otherwise , in a particular year cannot be a sole reason to believe that income has escaped assessment in earlier years.
Article Discusses Assessment under Section 143(1)-Scrutiny Assessment, Section 144- Best Judgement Assessment and Section 147- Income Escaping Assessment of Income Tax Act, 1961.
