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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.

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 ...

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High Court of Bombay Quashes Reopening Notice Against Assessee on Ground of Change of Opinion. Reassessment beyond four years not permissible when primary facts fully disclosed and no failure to disclose material facts.

The petitioner, a private limited company engaged in selling hair care products and providing consultancy services, challenged a notice dated 29 March...

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Supreme Court Allows Revenue Appeal in CENVAT Credit Case — Works Contract Service Classification Upheld. CENVAT Credit on Input Services for Works Contract Held Inadmissible Under Rule 2(l) of CENVAT Credit Rules, 2004.

The present appeal arises from a judgment of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) at Allahabad dated 09.11.2017, which allo...

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Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Failure to Disclose Material Facts. Reassessment After Four Years Invalid as Assessee Had Made Full Disclosure During Original Assessment Under Section 143(3).

The petitioner, Glaxosmithkline Pharmaceuticals Ltd., challenged a notice dated 28 March 2019 issued under Section 148 of the Income Tax Act, 1961 for...

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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.

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