#Section 148
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5,410 articlesIncome Tax

Income Tax
No Reopening of Assessment to be made on Audit Objections: Committee Recommends
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Reassessment not valid on mere information of investigation wing as no direct nexus establishes with income escapement
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Reassessment proceedings could not be declared as null and void where AO was prompted by correct information
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Mere reason to believe that income has escaped assessment not sufficient to reopen assessments beyond 4 years
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No new addition can be made in reopening on issue duly considered during original proceeding
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Reasons to reopen assessment must be tangible & should not merely be based on Investigation wing’s report
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Reassessment for taxing Royalty at higher rate due to change in opinion not valid
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Re-opening being exceptional power, revenue to comply pre-requisite condition of ‘reasons’ strictly
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Reopening u/s 147 based on mere office note of predecessor AO not permissible
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Assessment U/s. 147 not valid when time for scrutiny assessment U/s. 143(3) not lapsed
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Reopening by simply treating loan entry as income which has escaped from assessment is not appropriate
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Tangible material required to reopen assessment u/s 148 of Income Tax Act,1961
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In Reopening AO cannot pass Composite Order for Assessment and for rejection of objection
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