1. Harikishan S. Virmani v. DCIT
What is 1. Harikishan S. Virmani v. DCIT authority for?
Reassessment proceedings under section 147 cannot be initiated by the Assessing Officer based on borrowed satisfaction, vague information from the Investigation Wing, or incorrect jurisdictional facts without independent application of mind. Reopening beyond four years from the end of the relevant assessment year, especially where an original assessment was completed under section 143(3), requires specific conditions relating to the assessee's failure to disclose material facts.
judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2018 to 2026.
Also referred to as
Harikishan S. Virmani · DCIT · 394 ITR 146 · section 147 · section 148 · borrowed satisfaction · reopening beyond four years · section 143(3) assessment · investigation wing information · independent application of mind · reassessment validity
Also reported as
Sections most often in play
Issues it is cited on
Judgments citing 1. Harikishan S. Virmani v. DCIT
Showing 1–20 of 97 · Page 1 of 5