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Search Results for "reopen assessment"

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High Court

High Court of Karnataka Dismisses Revenue's Appeal in Capital Gains Tax Case — Conversion of Partnership Firm to Company Not a Transfer Under Section 2(47) of Income Tax Act. The court held that conversion of a partnership firm into a private company under the Karnataka Compulsory Conversion of Partnership Firms into Companies Act, 2014 does not constitute a 'transfer' for capital gains tax purposes.

3 Sep 2025

The Revenue filed an appeal under Section 260A of the Income Tax Act, 1961 against an order of the Income Tax Appellate Tribunal (ITAT) dated 15.10.20...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Assessment Year 2013-14 — Reopening Based on Same Issues Already Examined in Section 263 Proceedings Held Invalid as Change of Opinion. The Court held that reopening of assessment under Section 147 is not permissible when the same issues were already examined in revision proceedings under Section 263 and no fresh material exists.

20 Feb 2025

The petitioner, Dilip Gangaram Patil, is engaged in real estate business and filed his return of income for assessment year 2013-14 on 27 September 20...

High Court

Bombay High Court Allows Petition in Income Tax Reassessment Case Due to Change of Opinion. Reassessment under Section 148 of the Income Tax Act, 1961 cannot be based on a mere change of opinion on the same facts already examined.

26 Sep 2023

The petitioner, Knight Riders Sports Pvt. Ltd., which operates the Kolkata Knight Riders team in the Indian Premier League, challenged a notice dated ...

High Court

Bombay High Court Dismisses Petitioner's Challenge to Reopening of Assessment Under Section 147 of Income Tax Act, 1961 — Reopening Based on Tangible Material from Investigation Wing and Not a Mere Change of Opinion. Failure to Disclose Primary Facts During Original Assessment Justifies Reopening Within Four Years.

8 Sep 2023

The petitioner, Vaman Prestressing Co. Pvt. Ltd., filed two writ petitions challenging the reopening of its assessment for the Assessment Year 2006-07...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment based on mere change of opinion on share premium addition under Section 68 is invalid as all material was disclosed during original assessment.

10 Jul 2023

The petitioner, Rajshree Realtors Private Limited, a real estate company, filed its return of income for Assessment Year 2012-2013 declaring income of...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Housing Society — No Failure to Disclose Material Facts. Deduction Under Section 80P(2)(d) for Interest Income from Cooperative Banks Allowed as Assessee Had Disclosed All Relevant Details During Original Scrutiny Assessment.

15 Feb 2023

The Petitioner, Tahnee Heights CHS Ltd., a housing society registered under the Maharashtra Cooperative Societies Act, filed its return of income for ...

High Court

Bombay High Court Allows Petitioner in Income Tax Reassessment Case — Mushroom Farming Income Held Agricultural. Reassessment Notice Under Section 148 of Income Tax Act, 1961 Quashed as Based on Change of Opinion.

11 Apr 2018

The petitioner, Zuari Foods and Farms Pvt. Ltd., a private limited company engaged in mushroom farming, filed its income tax return for assessment yea...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 Income Tax Act for Mere Change of Opinion. Assessment Completed Under Section 143(3) Cannot Be Reopened Without Fresh Tangible Material.

19 Dec 2011

The petitioner, Sanand Properties Pvt. Ltd., filed a return for Assessment Year 2008-09 declaring income of Rs.20.33 lakhs, later revised to Rs.19.14 ...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 147 for Lack of Fresh Material — Reassessment Based on Same Facts as Original Assessment is Invalid. The Court held that the Assessing Officer cannot reopen an assessment on the same facts and material already considered during the original assessment under Section 143(3) of the Income Tax Act, 1961, as it amounts to a mere change of opinion.

10 Jun 2010

The Petitioner, Indian Oil Corporation Ltd., filed a writ petition challenging the reopening of its assessment for Assessment Year 2002-03 under Secti...

High Court

Bombay High Court Allows Petition Challenging Reopening of Assessment in Income Tax Case Due to Lack of Fresh Material. Notice under Section 148 issued beyond four years quashed as there was no failure to disclose material facts and the reasons constituted a change of opinion.

4 Mar 2010

The petitioner, Anil Radhakrishna Wani, a solicitor and advocate, was a partner of Little & Company and retired on 30 September 2002. Upon retirement,...

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