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Search Results for "reopening notice"

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High Court

Bombay High Court Dismisses Petition Challenging Reopening of Assessment Under Section 148 of Income Tax Act, 1961 Due to Suppression of Documents and Failure to File Timely Reply. Petitioner's failure to annex attachments to the petition and belated reply to show cause notice disentitled him from invoking extraordinary writ jurisdiction.

26 Feb 2025

The petitioner, Sanjay Patel, an individual, filed his return of income for assessment year 2017-18 on 3 August 2017. The return was selected for scru...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Reasonable Belief of Income Escaping Assessment. Share Premium Reassessment Based on Intrinsic Valuation Without New Material Held Invalid Under Section 147 of the Income Tax Act, 1961.

27 Jun 2023

The petitioner, SLS Energy Pvt. Ltd., challenged a notice dated 23 March 2015 issued under Section 148 of the Income Tax Act, 1961, for the assessment...

High Court

Bombay High Court Quashes Reassessment Notice Against Charitable Trust for Lack of Fresh Material. Reopening Beyond Four Years Invalid as No Failure to Disclose Material Facts Under Section 147 of Income Tax Act, 1961.

8 Mar 2023

The petitioner, Framji Dinshaw Petit Parsee Sanatorium, is a public charitable trust registered under section 12A of the Income Tax Act, 1961. For the...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Reassessment Based on Same Facts as Original Assessment is Invalid. The court held that a notice under section 148 cannot be issued on the same material already considered during scrutiny assessment under section 143(3), as it amounts to a change of opinion.

20 Feb 2023

The petitioner, Survival Technologies Pvt. Ltd., filed a writ petition challenging a notice dated 30 March 2021 issued under section 148 of the Income...

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 Not Permissible. The court held that the Assessing Officer cannot reopen an assessment on the same material already examined in the original assessment under Section 143(3) of the Income Tax Act, 1961.

10 Feb 2023

The petitioner, Bharat Amratlal Shah, challenged a notice dated 31 March 2021 issued under Section 148 read with Section 147 of the Income Tax Act, 19...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Reasonable Belief of Income Escaping Assessment. Reopening Beyond Four Years Without Fresh Material Constitutes Change of Opinion on Same Set of Facts.

11 Mar 2020

The petitioner, Gateway Leasing Pvt. Ltd., a non-banking financial company registered under the Companies Act, 1956, filed a writ petition under Artic...

High Court

Bombay High Court Quashes Reassessment Notices for Lack of Reasonable Belief of Income Escapement — Section 148 Income Tax Act, 1961. Reopening of assessments based on mere change of opinion without tangible material is invalid.

21 Dec 2016

The petitioner, Amar Hotchand Nagpal, a finance and estate broker, challenged three notices dated 23rd September 1997 issued under Section 148 of the ...

High Court

High Court of Karnataka Dismisses Assessee's Appeal in Income Tax Reopening Case — Reopening Notice Under Section 148 Held Valid Despite Limitation Argument. The court upheld the Tribunal's order confirming the addition of Rs.4,97,046/- as unexplained investments under Section 69 of the Income Tax Act, 1961.

14 Aug 2015

The appellant, Mrs. Maina Shetty, filed an appeal under Section 260-A of the Income Tax Act, 1961, challenging the order of the Income Tax Appellate T...

High Court

Bombay High Court Allows Petition Challenging Reassessment Notice Under Section 148 of Income Tax Act — Reassessment Based on Mere Change of Opinion Invalid as Full Disclosure Was Made During Original Assessment.

25 Mar 2015

The petitioner, Plus Paper Food Pac Ltd., filed a writ petition challenging a notice dated 18.11.2013 issued under Section 148 of the Income Tax Act, ...

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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