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Naresh Kumar Garg Vs ACIT (ITAT Delhi) When the grounds for reopening the reassessment do not exist any longer and no additions were ultimately made on that account, the addition in respect of the other items, which were not part of the ‘ reasons to believe’cannot be made. ITAT states that it is evident that […]
1. Section 148(1) The CG may by order, in respect of class of companies engaged in the production of such goods or providing such services, direct that particulars relating to the utilization of material or labour or to other items of cost shall also included in the books of account kept by that class of […]
Whether the Tribunal was justified in holding that the reopening of assessment was a result of mere change of opinion, even when there is no opinion formed or expressed by the Assessing Officer on this issue in the original assessment?
The issue under consideration is whether the addition made by AO merely based on the statement recorded under section 132(4) of the I.T. Act is justified in law?
The issue under consideration is whether the AO is correct in re-opening of the assessment under section 147 even though the assessee has disclose fully and truly all the material facts during original assessment?
Aince the AO has accepted the returned income for which reasons were recorded, therefore, for making any other addition, he should have issued fresh notice
The issue under consideration is whether the re-opening of assessment u/s 147 on the basis of wrong appreciation of facts can be sustained in law?
Mr. Jay Kishor Mishra, IRS (IT: 1993) CIT (DR)(ITAT)-4, Delhi jkmishrairs@gmail.com Mr. Jay Kishor Mishra is an officer of the 1993 batch of the Indian Revenue Service. He is a Graduate in Economics and Post Graduate in Sanskrit. He is an LLB and also holds Post Graduate Diploma in Management. Ms Sushama Singh, IRS (IT: […]
It is noticed that the department has lost the revenue in number of cases mainly on account of fatal mistake made by the AO in issuance of notice to dead person/ non-existent entity or in framing the assessment order in the name of dead person/non-existent entity.
ACIT Vs Shiv Vegpro Pvt. Ltd. (ITAT Jaipur) Reopening after 4 years in absence of failure of Assessee to disclose fully & truly all material facts necessary for assessment is invalid AO has even not mentioned as on what account or transactions the assessee has taken the accommodation entry from Shree Ram Trading Co. It […]
