Loading...

⚠ โœ•
❮ Top
☎ Help
Draft upto 3 replies to a
tax notice โ€” FREE ๐ŸŽ‰ โœ•

150 credits ยท 30 days

โ€ข Basic Search โ†’ 1 Credit
โ€ข Advanced Search โ†’ 3 Credits
โ€ข Drafter โ†’ 20 to extract + 25 per issue
(โ‰ˆ upto 2-3 drafts on us)

Already used our earlier 20-Credit Demo?
You are still eligible for this new 150-Credit Demo.

Activate your FREE Demo โ†’
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedbackโœ•

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
TMI Blog
Home / TMI Blogs / RSS

Second reassessment invalid where s.143(3) assessment completed and no new material or change in circumstances

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The ITAT dismissed the revenue's appeal and upheld the CIT(A)'s order quashing the second reassessment. The Tribunal held that once assessment under s.143(3) was completed, the AO could not reopen the assessment absent non-disclosure of material facts; the second reopening sought to re-examine the same issue of beneficial ownership and treaty entitlement relying on identical material already considered in the first reassessment. No new material was placed on record nor was there a permissible change in circumstances justifying reassessment. Consequently, the second reassessment was treated as a mere change of opinion and invalid, and the AO's action was set aside.....