Tag: satisfaction 148
Non-rejection of explanation in Assessment Order amounts to AO accepting it hence no reopening on change of opinion. SC upholds High Court judgment ABCAUS Case Law Citation:ABCAUS 3322 (2020) (06) SC In a recent judgment, the Hon’ble Supreme Court had dismissed the Special Leave Petition filed by the …
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 …
Affixture of income tax notice-essential conditions, procedure and law explained by ITAT. Unless notice is served on proper person in manner prescribed, service is insufficient and invalidates the jurisdiction of AO ABCAUS Case Law Citation:ABCAUS 3128 (2019) (08) ITAT Important case law relied upon by the parties:Vankat Naicken …
Reopening for verification of purchases from hawala dealer-Supreme Court dismisses SLP of the Department challenging dismissal of appeal by High Court ABCAUS Case Law Citation:ABCAUS 2745 (2019) (01) SC The Hon’ble Supreme Court has dismissed the Special Leave Petition (SLP) of the Income Tax Department against the decision …
Forming opinion on the basis of information received by Investigation wing does not amount to satisfaction of the AO to reopen the case u/s 147 – ITAT ABCAUS Case Law Citation: 975 2016 (07) ITAT Assessment Year: 2004-05 Date/Month of Judgment: July 2016 Important Case Laws/Judgments Cited: Pr. …
Writing “Yes, I am Satisfied” establishes non recording of proper satisfaction/approval before issue of notice u/s 148 No sooner than a week after, holding that merely writing “yes” or “approved” and affixing signature by CIT) was not the required satisfaction (ITA No. 5311/Del/2013 dated 07/04/2016), ITAT delhi Bench …
Merely writing yes/approved and affixing signature by CIT is not proper satisfaction for a fit case for re-opening u/s 147 and issue of notice u/s 148 Merely writing “yes” or “approved” and affixing signature by the Commissioner of Income Tax (CIT) was not the required/proper satisfied for a fit case …
