| COURT: | ITAT Kolkata |
| CORAM: | Mahavir Singh (JM), Shamim Yahya (AM) |
| SECTION(S): | 147, 148 |
| GENRE: | Domestic Tax |
| CATCH WORDS: | application of mind, non-speaking order, Reopening |
| COUNSEL: | Somnath Ghosh |
| DATE: | October 14, 2014 (Date of pronouncement) |
| DATE: | October 21, 2014 (Date of publication) |
| AY: | 2007-08 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| Failure to record detailed reasons in assessment order does justifying s. 147 action. There is a statutory presumption that AO has applied his mind while passing assessment order | |
Section 147 of the Act, as substituted w.e.f. 01.04.1989 does not postulates conferment of power upon the AO to initiate reassessment proceeding upon his mere change of opinion. Further, if ‘reason to believe’ of the AO is founded on an …
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