Tag: reopening 148
Assessee must be put to notice of all provisions on which revenue relies upon. Supreme Court quashed reopening notice u/s 148 ABCAUS Case Law Citation:ABCAUS 3293 (2020) (04) SC Important case law relied upon by the parties:Claggett Brachi Co. Ltd. London 1989 Supp(2) SCC 182M/s Phool Chand Bajrang …
Reopening quashed as AO not recorded reasons of assesse’s failure to disclose material facts fully and truly but notice u/s 148 was issued on change of opinion ABCAUS Case Law Citation:ABCAUS 3236 (2020) (01) ITAT Important case law relied upon by the parties:Sadbhav Engineering Ltd. vs. DCITCIT Vs. …
Notice u/s 148 approval recording satisfaction “Yes, I am satisfied on the reasons recorded by the AO that it is a fit case for issue of notice u/s. 148 of the I.T. Act.” invalid ABCAUS Case Law Citation:ABCAUS 3228 (2020) (01) ITAT Important case law relied upon by …
Reassessment u/s 148 due to credit card payment. ITAT directed AO to delete the addition made in view of returned income of the assessee ABCAUS Case Law Citation:ABCAUS 3197A (2019) (12) ITAT The instant appeal was filed by the assessee against the order of the CIT(A) in the …
Directions u/s 144A does not affect applicability of decision of the Supreme Court in GKN Driveshaft for disposing off objections to reopening ABCAUS Case Law Citation:ABCAUS 3173 (2019) (10) HC Important case law relied upon by the parties:M/s. Deepak Extrusions Pvt. Ltd. vs. The Deputy Commissioner of Income …
Reopening done at the insistence of CIT held as change of opinion and was vitiated in law as it did not satisfy the legal requirement of Section 147 of the Act ABCAUS Case Law Citation:ABCAUS 3124 (2019) (08) HC Important case law relied upon by the parties:Larsen and …
ITAT authorised to consider question of jurisdiction raised first time and not raised earlier as it goes to the root of the matter and substantially affects the rights of assessee ABCAUS Case Law Citation:ABCAUS 3111 (2019) (08) ITAT Important case law relied upon by the parties:National Thermal Power …
Reopening u/s 148 alleging evidence discovered with due diligence quashed as no specific failure on part of the assessee was stated. SC dismisses SLP of the Department ABCAUS Case Law Citation:ABCAUS 3110 (2019) (08) SC The respondent assessee was a company. For the relevant assessment year it had …
Reopening for not replying to invalid and non est inquiry letter for cash deposited in bank quashed. Deposit per se cannot be income of assessee. ABCAUS Case Law Citation:ABCAUS 3106 (2019) (08) ITAT Important case law relied upon by the parties:Tajendra Kumar Ghai Vs ITO In the instant …
Change of opinion not permissible for invoking proceedings u/s 147. ITAT quashed reassessment for payment of managerial remuneration in proprietorship firm ABCAUS Case Law Citation:ABCAUS 3099 (2019) (08) ITAT Important case law relied upon by the parties:CIT v. Kelvinator of India Ltd.: 320 ITR 561(SC) The instant appeal …
