S. 147 : Reassessment – After the expiry of four years -Settlement amount paid to employees–Penalty -Information from Investigation Wing – No material available on record other than information from Investigation Wing to prove that payment made was penalty,- Reopening was quashed. [S. 37(1), 148, Art. 226 ]
S. 147 : Reassessment–After the expiry of four years – Scientific research expenditure–No failure to disclose material facts – Reassessment notice and order disposing the objection was quashed. [S. 35(2AB), 148, 154, Art, 226]
S. 147 : Reassessment – After the expiry of four years – Sale and lease back -100 percent depreciation – No failure to disclose material facts – Reassessment notice and order disposing the objection was set aside. [S. 32, 148, Art. 226]
S. 147 : Reassessment – After the expiry of four years – No failure to disclose material facts – Reassessment notice and order disposing the objection was quashed. [S. 28(i), 143(3), 148, Art. 226]
S. 147 : Reassessment – After the expiry of four years – Reversal of transfer of TDR of a land – Capital or Revenue – No new material – Reassessment notice and order disposing the objection was quashed. [S. 28(i), 148, Art. 226]
S. 147 : Reassessment–After the expiry of four years – Carry forward and set-off of deficit – Change of opinion – Reassessment notice and order disposing the objection was quashed. [S. 11(1)(a), 12, Art. 226]
S. 147 : Reassessment–After the expiry of four years -Capital gains –Reassessment notice was issued only on the basis of information received on insight portal – No tangible material – Reassessment notice was quashed. [S. 10(38), 143(3) 148, Art. 226]
S. 147 : Reassessment–After the expiry of four years – Capital gains – Transfer- Development rights – Power of Attorney – Neither any tangible material nor any reason to believe that ‘any income chargeable to tax had escaped assessment’ – Reassessment notice was quashed. [S. 2(47)(v), 148, Transfer of Property Act, 1882, S.53A, Art. 226]
S. 147 : Reassessment–After the expiry of four years – Same material available on record-Change of opinion-Notice and order rejecting objections set aside. [S. 148, Art, 226]
S. 147 : Reassessment – After the expiry of four years – Penny Stock -Share transactions and tax paid on added income – No new tangible material – Accommodation entries – Reconsideration of the material available at the time of original assessment proceedings is tantamount to change of opinion – Reassessment notice and order disposing the objection was quashed. [S. 10(38), 45 69, 148, Art. 226]