#Section 147
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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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AO cannot assess other ‘escaped income’ if reason for issue of Notice under section 148 dropped
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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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