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Melvillie Finvest Ltd., 63666/B, ... vs Incometax Officer, Ward 21, Aayakar ... on 19 June, 2025
cites
Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 154 in The Income Tax Act, 1961 [Entire Act]
Section 73 in The Income Tax Act, 1961 [Entire Act]
Section 153 in The Income Tax Act, 1961 [Entire Act]
Mahalaxmi Motors Ltd. vs Deputy Commissioner Of Income-Tax And ... on 10 November, 2003
4) Mahalaxmi Motors Ltd. vs. Deputy Commissioner of
Income-tax and Another 7
4
(2023) 458 ITR 566
5
(2010) 2 SCC 723
6
2003 SCC OnLine P&H 1818
Page 8 of 16
wp_22221_2003
PSK,J,J&NNR,J
Commnr. Of Income Tax, Delhi vs M/S. Kelvinator Of India Ltd on 18 January, 2010
147.-A number of representations were received against the
omission of the words `reason to believe' from Section 147 and
their substitution by the `opinion' of the Assessing Officer. It
was pointed out that the Commnr. Of Income Tax, Delhi vs M/S.
Kelvinator Of India Ltd on 18 January, 2010 meaning of the
expression, `reason to believe' had been explained in a number
of court rulings in the past and was well settled and its
omission from Section 147 would give arbitrary powers to the
Assessing Officer to reopen past assessments on mere change
of opinion. To allay these fears, the Amending Act, 1989, has
again amended Section 147 to reintroduce the expression `has
reason to believe' in place of the words `for reasons to be
recorded by him in writing, is of the opinion'. Other provisions of
the new Section 147, however, remain the same."