#Section 148
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5,409 articlesIncome Tax
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S. 147 Reopening based on material placed before DRP considering the same as new material
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Reasons for initiating assessment u/s 147 should be recorded prior to issuance of notice u/s 148
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Section 148 could not be invoked in absence of any Tangible Material
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Reopening U/s 147 – `Incessant Trip to Litigation’
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Reopening based on mere information received from Income Tax Investigation Wing not valid
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Reassessment not justified if assessee had disclosed all the material facts and provided necessary documents during assessment proceedings
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Income Tax
Section 147: Power of Review V/s Power to Re Assess
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If AO not conducted proper inquiry, the obligation to do so is on CIT(A) & ITAT
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Merely Approval without application of mind not sufficient and renders reopening void
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Reopening on mere ground of Cash Deposit in Bank Account not Valid
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Whenever order of Re-assessment is passed, Period of Limitation will start from the date of Re-assessment order and not from Original Assessment order
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For invoking reassessment proceedings, reasons has to be recorded & not conclusions
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Income Tax
Section 153C Assessment of income of a person other than the person in whose case search has been initiated
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Income Tax
