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Search Results for "reopening of assessment"

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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 Allows Writ Petition Challenging Reopening of Assessment Under Section 148 of Income Tax Act, 1961 — Quashes Notice as Barred by Limitation and Lacking Fresh Material. Reopening beyond four years requires failure to disclose material facts, and reopening on same material as original assessment is impermissible change of opinion.

10 Nov 2023

The petitioner, DCW Limited, challenged a notice dated 30th June 2021 issued under Section 148 of the Income Tax Act, 1961 seeking to reopen its asses...

High Court

Bombay High Court Allows Writ Petition Challenging Reopening of Assessment Beyond Four Years Under Section 147 of Income Tax Act, 1961 — No Failure to Disclose Material Facts. Reopening Based on Change of Opinion Not Permissible; Notice Under Section 148 Quashed.

8 Nov 2023

The petitioner, Hasmukh Estates Pvt. Ltd., a company registered under the Companies Act, 1956/2013, filed a writ petition under Article 226 of the Con...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Gift of Property by Company to Director's Husband Held Not to be Income, as Assessee's Objections Were Not Properly Considered.

6 Oct 2023

The petitioner, Bakhtawar Construction Co. Pvt. Ltd., a closely held company, challenged a notice dated 30 March 2013 issued under Section 148 of the ...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment Based on Same Material as Original Assessment Without New Tangible Information is Invalid.

6 Oct 2023

The petitioner, an individual assessee, filed his return of income for Assessment Year 2006-07 on 26 October 2007 declaring total income of Rs.2,84,19...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income-tax Act, 1961 for Lack of Fresh Material. Assessment Reopened Beyond Four Years Based on Reappraisal of Same Facts Without Allegation of Failure to Disclose Material Facts Held Invalid.

25 Sep 2023

The petitioner, CitiusTech Healthcare Technology Pvt. Ltd., filed a writ petition challenging a notice dated 27 March 2021 issued under Section 148 of...

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 Allows Writ Petition Challenging Reopening of Assessment Under Section 148 of Income-tax Act, 1961 — Notice Barred by Limitation Under Section 149. Declaration Under Income Declaration Scheme, 2016 Deemed Never Made Due to Default in Instalments; Revised Return Filed; Reopening Notice Issued Beyond Time Limit Quashed.

28 Aug 2023

The petitioner, an individual, filed a declaration under the Income Declaration Scheme, 2016 (IDS) declaring undisclosed income. The scheme required p...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Full and True Disclosure — Petitioner Had Disclosed All Material Facts in Return of Income. The court held that the reopening was based on a change of opinion and was invalid as the Assessing Officer did not form a reasonable belief of escapement of income.

7 Aug 2023

The petitioner, Astec LifeSciences Ltd., is engaged in the business of manufacturing and trading of agrochemicals and pharmaceutical intermediates. Wi...

High Court

Bombay High Court Quashes Reassessment Notice for TCS in Income Tax Case — Lack of Fresh Material and Change of Opinion. Reopening under Section 147 of Income Tax Act, 1961 invalid as reasons recorded were based on same material considered during original assessment, constituting mere change of opinion.

27 Jun 2023

The petitioner, Tata Consultancy Services Ltd., challenged a notice dated 31st March 2021 issued under Section 148 of the Income Tax Act, 1961 seeking...

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