Tag Archive: reason recorded

Section 147,148, 151 Consequences when the A.O. mentioned wrong Section, wrong facts in the reasons for reopening of the assessment and acted in a mechanical manner without application of mind. ITAT Delhi in the case of Maheshwari Roller Flour Mills Pvt … vs Ito on 17 December, 2020 AY 2009-10. In favour of assessee. ITA.No.4257/Del./2019.

Section 147,148, 151 Consequences when the A.O. mentioned wrong Section, wrong facts in the reasons for reopening of the assessment and acted in a mechanical manner without application of mind. ITAT Delhi in the case of Maheshwari Roller Flour Mills…
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147, 148, 151, 151(1), AY 2009-10, Concealment of income, Disposal of objection, In Favour of Assessee, Reassessment, Speaking order

Section 147,148, 151. Consequences when the Ld. AO failed to provide the complete Annexures which are the basis for reopening ? The ITAT Delhi passed the order on 15 January, 2020 in the case of Behat Holdings Ltd., New Delhi vs Ito Ward-4(3), New Delhi Order in the favour of the assessee. ITA.No.8066/Del./2019.

Section 147,148, 151. Consequences when the Ld. AO failed to provide the complete Annexures which are the basis for reopening ? The ITAT Delhi passed the order on 15 January, 2020 in the case of Behat Holdings Ltd., New Delhi…
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147, 148, 151, 151(1), AY 2010-11, borrowed satisfaction, Concealment of income, Decisions, Delhi, Delhi Tribunal, In Favour of Assessee, ITAT Delhi, Order Quashed

Consequences when the Assessing Officer was not specific as to on what basis the Assessing Officer has the reason to believe that the income of the assessee has escaped assessment. Answer was given in the case of DUGGAL ESTATES PVT. LTD. & ANR. vs. ITO ITAT DELHI, May 24, 2021, Section 147, 148 AY 2009-10. https://www.bpmundraca.com/it-cases-241-2021/

Consequences when the Assessing Officer was not specific as to on what basis the Assessing Officer has the reason to believe that the income of the assessee has escaped assessment. Answer was given in the case of DUGGAL ESTATES PVT….
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147, 148, Assessment is Null and void, AY 2009-10, Delhi Tribunal, Disposal of objection, In Favour of Assessee, Reason recorded, Speaking order

The question in the present case is as to whether the information received from the investigation wing/search team would constitute ‘reason to believe’ empowering the Assessing Officer to reopen the assessment u/s 147/148. Answer is given by ITAT Ahmedabad on 12/11/2020 in the case of Hitesh Ashok Vaswani Vs DCIT. https://www.bpmundraca.com/it-cases-240-2021/

Reopening u/s 147/148 at the instance of information received from DDI wing Hitesh Ashok Vaswani Vs DCIT (ITAT Ahmedabad) Appeal Number : IT(SS)A No. 118 to 123/Ahd/2019 Date of Order : 12/11/2020 AY: 2009-10 to 2014-15 The question in…
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147, 148, 151, 153, Ahmedabad Tribunal, AY 2009-10, AY 2010-11, AY 2011-12, AY 2012-13, AY 2013-14, AY 2014-15, borrowed satisfaction, Concealment of income, In Favour of Assessee, In favour of Assessee (Partly)

ITAT KOLKATA on Mar 13, 2020 quashed the reopening of assessment and allow this appeal of the assessee on the ground that the re-opening is bad in law as the Assessing Officer has not independently applied his mind to the material and recorded reasons which are vague and merely based on borrowed satisfaction.

ITAT KOLKATA on Mar 13, 2020 quashed the reopening of assessment and allow this appeal of the assessee on the ground that the re-opening is bad in law as the Assessing Officer has not independently applied his mind to the…
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147, AY 2011-12, bogus, borrowed satisfaction, In Favour of Assessee, Kolkata tribunal, Reason recorded, Satisfaction

Reassessment proceedings u/s 147 r.w.s 148 of the Act cannot be initiated after expiry of 4 years from the end of the relevant assessment year unless there is a failure on the part of the assessee to disclose fully and truly all material facts

………Re- assessment proceedings u/s 147 r.w.s 148 of the Act cannot be initiated after expiry of 4 years from the end of the relevant assessment year unless there is a failure on the part of the assessee to disclose fully…
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148, Articles, Cases Income tax

November 15, 2019