Tag: Reopening us 147
Reason recorded by non jurisdictional Assessing Officer cannot give jurisdiction to the jurisdictional Assessing Officer. ABCAUS Case Law CitationABCAUS 3449 (2021) (02) ITAT Important case law relied referred:Pankaj Bhai Jayshuklal Shah vs. CIT (2020) 425 ITR 70Manoj Kumar vs. ACIT reported 79 ITR (Tribunal) 158 Delhi In the …
Amendments made to provisions of Income escaping assessment and search assessments by Budget 2021-22. Revised time limit for issuing notice Under the existing provisions, the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he may reopen the …
Filing belated return & non-registration u/s 12AA no valid reasons to issue notice u/s 148 in absence of other tangible material other than return filed ABCAUS Case Law CitationABCAUS 3442 (2021) (01) ITAT In the instant case, the assessee had challenged the order passed by the CIT(A) in …
Reassessment held bad in law as assessee not given four weeks time to seek legal remedy after rejection of objections to reopening ABCAUS Case Law CitationABCAUS 3438 (2021) (01) ITAT Important case law relied upon by the parties:Smt. Kamlesh Goel vs. Income Tax OfficerPr. CIT vs. Sagar DeveloperBharat …
Addition made on the basis of cancelled money receipt found during search quashed as its contents was not confronted with issuer ABCAUS Case Law CitationABCAUS 3401 (2020) (10) ITAT Important case law relied upon by the parties: In the instant case, the assessee had challenged the order passed …
Reassessment made by issue of notice 143(2) before filing of return of income is invalid and not sustainable in the eyes of law ABCAUS Case Law CitationABCAUS 3394 (2020) (09) ITAT Important case law relied upon by the parties:Singhad Technical Society 397 ITR 344.Fast Booking (I) Pvt. Ltd. …
Reassessment quashed as void ab-initio for service of notice u/s 148 at wrong address when assessee had communicated changed new address ABCAUS Case Law CitationABCAUS 3392 (2020) (09) ITAT In the instant case, the assessee had challenged the order passed by the CIT(A) in rejecting the objection raised …
Without cogent reasons for belief towards escapement, even a non-filer can not be forced to file a return u/s 147. ITAT held notice u/s 147 bad in Law ABCAUS Case Law CitationABCAUS 3391 (2020) (09) ITAT Important case law relied upon by the parties:Shri Ravindrasinh N. Gohil vs. …
CIT need not to given separate reasons for his satisfaction in giving approval u/s 151 for reopening of assessment if reasons recorded by AO have a direct nexus with the information and formation of belief of income escapement. ABCAUS Case Law CitationABCAUS 3388 (2020) (09) ITAT Important case …
Assessee not permitted to change head of income as per his own sweet will and convenience. ITAT upheld addition following consistency rule ABCAUS Case Law Citation:ABCAUS 3341 (2020) (07) ITAT Important case law relied upon by the parties:Chennai Properties & Investments Ltd. v/s CIT, 373 ITR 673 (SC)Rayala …
