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Search Results for "reopening notice"

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High Court

High Court of Bombay Stayed Impugned Re-Assessment Proceedings Under Income Tax Act – Challenge to Section 148 Notice for AY 2009-2010. Petition Filed Against Order Rejecting Objections and Seeking Re-Opening of Assessment Under Section 148 of the Income Tax Act, 1961.

25 Apr 2025

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High Court

Bombay High Court Quashes Reassessment Notice and Order in Income Tax Case Due to Lack of Full and True Disclosure Finding and Non-Disposal of Objections. Reopening Beyond Four Years Invalid as No Failure to Disclose Material Facts Alleged Under Section 147 First Proviso of Income Tax Act, 1961.

27 Feb 2025

The petitioner, Crystal Pride Developers, a partnership firm engaged in real estate development, filed its original return of income for Assessment Ye...

High Court

Bombay High Court Allows Writ Petitions Challenging Reopening of Assessments Under Section 147 of Income Tax Act, 1961 — Reopening Based on Change of Opinion and Non-Disclosure of Material Facts Held Invalid. The court held that reassessment notices issued without tangible material and based on a change of opinion are invalid, and that the assessee's failure to disclose primary facts is a prerequisite for invoking the proviso to Section 147.

19 Jan 2024

The judgment pertains to two writ petitions filed by corporate assessees challenging the reopening of their income tax assessments for the assessment ...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 148 of Income Tax Act for Lack of Fresh Material — Petitioner Had Disclosed All Facts in Original Assessment Under Section 143(3).

13 Mar 2023

The petitioner, Milton Plastics Limited, filed a writ petition under Article 226 of the Constitution of India challenging a notice dated 22.03.2004 is...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment Based on Change of Opinion on Deduction Under Section 10AA of Income Tax Act, 1961 is Invalid.

10 Jan 2022

The petitioner, Oracle Financial Services Software Limited, is a company engaged in providing information technology solutions to banks and financial ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material. Reopening Based on Change of Opinion on Already Disclosed Loan Transactions is Invalid.

24 Aug 2021

The petitioner, Jainam Investments, a partnership firm engaged in trading of shares and securities, filed its income tax return for Assessment Year 20...

High Court

Bombay High Court Allows Writ Petition Challenging Reopening of Assessment Under Section 148 of Income Tax Act, 1961 Based on Change of Opinion. Reassessment Notice and Order Quashed as Assessing Officer Had No Fresh Tangible Material to Justify Reopening.

11 Feb 2014

The petitioner, Aroni Commercials Limited, challenged a notice dated 28 March 2013 under Section 148 of the Income Tax Act, 1961 seeking to reopen its...

High Court

Bombay High Court Allows Petition Challenging Reopening of Assessment Under Section 148 of Income Tax Act, 1961 — Reopening Based on Mere Change of Opinion Without Fresh Material Held Invalid.

3 May 2013

The petitioner, M/s. Rabo India Finance Limited, challenged the reopening of its income tax assessment for Assessment Year 2006-07 under Section 148 o...

High Court

Bombay High Court Quashes Reopening Notices Under Section 148 of Income Tax Act for Assessment Years 2005-06 to 2008-09 Due to Lack of Failure to Disclose Material Facts and Change of Opinion. Remuneration Paid to Directors Was Fully Disclosed and Examined During Original Assessment, So Reopening Invalid.

20 Feb 2013

The petitioner, M/s. OHM Stock Brokers Pvt. Ltd., a share and stock broker, challenged notices under Section 148 of the Income Tax Act, 1961 for reope...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reopening Case — Notice Based on Mere Change of Opinion Invalid. Reopening of assessment under Section 148 of the Income Tax Act, 1961 within four years held bad in law when based on change of opinion regarding deduction under Section 36(1)(viii).

9 Jul 2012

The appeal was filed by the Commissioner of Income Tax-3, Mumbai (revenue) under Section 260A of the Income Tax Act, 1961 against the order dated 27/8...

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