#Section 148
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Re-Opening of Assessment u/s 147 Merely Relying upon Investigation Report Not Justified in Law
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Reassessment based on Invalid Facts with no Application of Mind is Invalid
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Complemented Assessment cannot be reopened U/s. 147/148 on Borrowed Satisfaction
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Section 147/148 proceedings on mere investigation wing information was not valid
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Section 80P deduction can be claimed while filing return in response to Section 148
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Additions in reopened Assessment not valid if no addition on subject matter of reopening
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Conditions Precedent for Reopening of Assessment beyond 4 Year- Section 147
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In absence of new facts reopening of already examined issue was invalid
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No reopening if no failure of assessee to disclose fully & truly all material facts necessary for assessment
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Validity of reopening based on Survey finding on ineligibility to claim Section 80IA Deduction
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No reopening of Assessment after 4 Year if no failure of Assessee in disclosing relevant facts
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AO cannot take second view on same set of facts treating earlier view as erroneous
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No reopening of Assessment for mere client code modification
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