Tag: Sec 147

  • Useful Income Tax Case Laws / Order

    Useful Income Tax Case Laws / Order

    1. Sec. 45 – Capital gains v. Business income – Consistency – Earlier years’ position – No change of facts in current year. Assessee earned income from short term capital gain of Rs. 32,82,775/-. AO treated assessee as trader and taxed the capital gains as business income. Held, that in previous years, the assessee was…

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  • Sec 147 of Income Tax Act- Initiation of reassessment proceedings

    Sec 147 of Income Tax Act- Initiation of reassessment proceedings

    Only jurisdictional AO can form reason to believe for purpose of initiation of reassessment proceedings : ITAT

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