S. 147 : Reassessment-After the expiry of four years-Depreciation-No failure to disclose material facts necessary for assessment-Notice and order disposing the objection is quashed. [S. 32, 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Depreciation-No failure to disclose material facts necessary for assessment-Notice and order disposing the objection is quashed. [S. 32, 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Depreciation-No failure to disclose material facts necessary for assessment-Notice and order disposing the objection is quashed. [S. 32, 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Accommodation entries-Internal information-No live link between material and belief- Change of opinion-Reassessment notice and order disposing the objection is quashed.[S. 143(3), 148, Art. 226, Evidence Act, 1872, S.103]
S. 147 : Reassessment-After the expiry of four years-No failure on the part of assessee to disclose fully and truly all material facts-Notice and order disposing the objection is set aside. [S. 54, 54F, 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-No failure on the part of the assessee to disclose fully and truly all material facts-Notice and order disposing the objection is quashed and set aside [S.10AA, 148, Form No 56F, Art.226]
S. 147 : Reassessment-After the expiry of four years-No new information-Disclosed all material facts fully and truly- Allegation of paper companies-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 148, Art.136]
S. 147 : Reassessment-After the expiry of four years-Full and true disclosure-Change of opinion-Books seized not returned-Unable to draw balance-sheet-Subsequently drawing the balance sheet-Assessment under section 143(3) of the Act-Return not treated as defective-Subsequent subjective analysis of Assessing Officer that income of assessee was much higher than that assessed- Change of opinion- Reassessments are not justified-Once primary facts disclosed by assessee, burden shifts to Assessing Officer-Defective return-Burden on Assessing Officer to intimate defect to Assessee for rectification within time specified- Assessing Officer not exercising discretion- Return cannot be construed as defective burden on Assessing Officer to intimate defect to Assessee for rectification within time specified. [S. 139(9)(f), 145(1) 147, 149(1)(b)(iii)]
S. 147 : Reassessment-After the expiry of four years-Different method of accounting-Capital gains-Computation-No failure to disclose material facts-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 45, 48, 112(1)(c)(ii), 143(3) 148, Art, 136]
S. 144C : Reference to dispute resolution panel-Order passed under remand proceedings also has to follow mandatory procedure-Final assessment order without following the procedure is bad in law and unlawful.[S. 144BA(12), 144C(14A),263 Art.226]
S. 143(3): Assessment-CBDT Circular No. 14 Of 1955- Duty of Assessing Officer to grant relief to assessee even if not claimed-DTAA-India-USA.[S.119, 139,143(1), 260A, art.12]