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Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
<h1>Tax Reassessment Blocked: Independent Evaluation Required for Reopening Assessment Under Section 147 Confirmed by Supreme Ruling</h1> SC held that a District Valuation Officer's opinion alone is insufficient to reopen a tax assessment under section 147. The Assessing Officer must ... Reopening of assessment under section 147 of the Income-tax Act, 1961 - opinion of the District Valuation Officer not constituting information for reopening - Assessing Officer's formation of belief after applying mind to informationReopening of assessment under section 147 of the Income-tax Act, 1961 - opinion of the District Valuation Officer not constituting information for reopening - Assessing Officer's formation of belief after applying mind to information - Reopening of assessment premised solely on the opinion of the District Valuation Officer was not permissible under section 147. - HELD THAT: - The Court held that the DVO's opinion by itself does not amount to 'information' justifying reopening under section 147. The Assessing Officer is required to apply independent mind to any information collected and must form a bona fide belief before invoking the reopening provision. Since the Department relied only on the DVO's opinion without an exercise of mind culminating in the Assessing Officer's belief, the statutory requirement for reopening under section 147 was not satisfied and the reopening was therefore not justified. [Paras 1]The reopening based on the DVO's opinion was invalid and the Department was not entitled to reopen the assessment.Final Conclusion: Civil appeal dismissed; the Department's reopening of assessment founded solely on the DVO's opinion was quashed for failure of the Assessing Officer to apply his mind and form the requisite belief under section 147. The Supreme Court of India held that the opinion of the District Valuation Officer (DVO) alone does not constitute 'information' sufficient to reopen an assessment under section 147 of the Income-tax Act, 1961. The Assessing Officer must independently apply mind to any information collected and form a belief to justify reopening. Consequently, the Department was not entitled to reopen the assessment. The civil appeal was dismissed with no order as to costs.
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