The Honorable Supreme Court in its judgement dated 11th September, 2012 has held that change in legal position due to reversal of a judgement by a higher court is not a valid ground for reopening of assessment u/s 147 when the assessment was finalised on the basis of law in force at the time of…
Reassessment u/s 147 cannot be initiated if Assessing Officer misinterpreted legal provisions in original assessment
legal misinterpretation by Assessing Officer in framing original assessment cannot be the basis of initiation of Assessment Proceeding u/s 147
Reassessment u/s 147: No addition can be made on other grounds when the reasons for which reassessment undertaken cease to survive
no addition can be made on other grounds, if the Assessing Officer doesn’t make any addition on the primary ground on the basis of which proceeding u/s 147 were initiated.