https://www.taxtmi.com/caselaws?id=449015 HC quashed reopening under section 147, holding recorded reasons did not dispute issuance of shares or receipt of premium and merely questioned quantum of premium, which cannot sustain belief of escaped income for AY 2009-10. Amendments to provisions governing share premium and deemed income applied from AY 2013-14 and were inapplicable, so AO lacked jurisdiction to reopen. AO's reasons were speculative, ignored balance sheet and valuation report, and were based on superior's communication rather than independent satisfaction. Reopening and notice set aside; decision for the taxpayer. en-us Thu, 01 Feb 2024 00:00:00 +0530 Tue, 28 Jul 2026 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449015 HC quashed reopening under section 147, holding recorded reasons did not dispute issuance of shares or receipt of premium and merely questioned quantum of premium, which cannot sustain belief of escaped income for AY 2009-10. Amendments to provisions governing share premium and deemed income applied from AY 2013-14 and were inapplicable, so AO lacked jurisdiction to reopen. AO's reasons were speculative, ignored balance sheet and valuation report, and were based on superior's communication rather than independent satisfaction. Reopening and notice set aside; decision for the taxpayer. Case-Laws Income Tax Thu, 01 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449015