Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Validity of reopening of assessment u/s 147 - order passed u/s 148A(d) - reason to believe - The High Court observed that, the assessing officer would state that no prudent businessman will simply withdraw crores of cash from his bank account and again will deposit it at various stage. This is a personal opinion of the assessing officer. However, for the purpose of reopening an assessment there should be a tangible material placed by the assessing officer to show that there was escapement of income from the payment of income tax. - The HC allowed the appeal and the order passed u/s 148A(d) and the consequential notice u/s 148 of the Act are quashed
Validity of reopening of assessment u/s 147 - order passed u/s 148A(d) - reason to believe - The High Court observed that, the assessing officer would state that no prudent businessman will simply withdraw crores of cash from his bank account and again will deposit it at various stage. This is a personal opinion of the assessing officer. However, for the purpose of reopening an assessment there should be a tangible material placed by the assessing officer to show that there was escapement of income from the payment of income tax. - The HC allowed the appeal and the order passed u/s 148A(d) and the consequential notice u/s 148 of the Act are quashed
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