#Section 147
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Validity of notice u/s 148 for re-opening of assessment when jurisdiction was founded merely on the possibility of escapement
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S.148 notice after 4 years not valid if Assessee disclosed full & true particular of claim at the time of original assessment proceeding
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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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Income Tax
