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Search Results for "reopening after four years"

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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 — Prior Scrutiny Assessment Cannot Be Reopened on Same Issues Without New Tangible Material

27 Jun 2023

The petitioner, Maharashtra State Power Generation Company Limited, a company engaged in electricity generation for the State of Maharashtra, challeng...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material. Reopening Based on Mere Change of Opinion on Allowability of Sales Promotion and Physician Sample Expenses is Invalid.

10 Feb 2023

The petitioner, Abbott India Limited (successor of Solvay Pharma India Ltd.), challenged a notice dated 27 March 2015 issued under Section 148 of the ...

High Court

Bombay High Court Allows Writ Petition Challenging Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment Notice Quashed as Based on Mere Change of Opinion Where Original Assessment Under Section 143(3) Had Examined Section 54 Exemption Claim.

15 Mar 2022

The petitioner, Gagan Omprakash Navani, an individual assessed to tax, filed a return of income for Assessment Year 2016-2017 on 10 April 2017, declar...

High Court

Bombay High Court Quashes Reassessment Notices in Income Tax Case Due to Lack of Reason to Believe — Deemed Dividend Addition Based on Incorrect Facts and Non-Application of Mind. The court held that the Assessing Officer must apply his own mind to tangible material before issuing a notice under Section 148 of the Income Tax Act, 1961, and that reopening on the same facts without new material amounts to a change of opinion.

17 Feb 2022

The petitioners, Pavan Morarka and Rachna Morarka, were shareholders in Shivum Holdings Pvt. Ltd. (Shivum) and P&A Estate Pvt. Ltd. (P&A). During the ...

High Court

Bombay High Court at Goa Quashes Reopening Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material and Change of Opinion. Assessment Reopening After Four Years Invalid Without Failure to Disclose True and Full Facts.

18 Feb 2020

The petitioner, M/s. Anand Developers, a partnership firm, challenged a notice dated 29 March 2019 issued under Section 148 of the Income Tax Act, 196...

High Court

Bombay High Court Allows Assessee's Petition in Income Tax Reassessment Case Due to Change of Opinion. Reopening of Assessment Under Section 147 of Income Tax Act, 1961 Set Aside as No Fresh Tangible Material Existed After Original Assessment Under Section 143(3).

8 Mar 2010

The petitioner, Skol Breweries Ltd., challenged the reopening of its income tax assessment for assessment year 2004-05 by the Deputy Commissioner of I...

High Court

Bombay High Court Allows Petitioner in Income Tax Reopening Case — Notice Under Section 148 Quashed as Beyond Four Years Without Failure to Disclose. Reopening of Assessment Based on Change of Opinion Held Invalid Under Section 147 of Income Tax Act, 1961.

17 Feb 2010

The petitioner, Multiscreen Media Private Limited, a company engaged in providing audiovisual television software, films, events, and related activiti...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material Beyond Four Years. Reopening of Assessment Under Section 148 of Income Tax Act, 1961 Held Invalid as There Was No Failure to Disclose Material Facts and No New Tangible Material.

17 Feb 2010

The petitioner, Multiscreen Media Private Limited, a company engaged in providing audiovisual television software and related activities, filed return...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 147 of Income Tax Act, 1961 for Lack of Full and True Disclosure. Deduction Under Section 80M Allowed Based on Dividend Distributed Before Due Date.

11 Feb 2010

The petitioner, Godrej Agrovet Limited, a domestic company, filed its return of income for Assessment Year 2003-04 on 27th November, 2003 declaring an...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material. Section 148 Notice for AY 2002-03 Set Aside as Assessing Officer Failed to Disclose Any New Information or Change of Opinion After Original Assessment Under Section 143(3).

12 Jan 2010

The petitioner, M/s Bhavesh Developers, a firm engaged in the business of developing and constructing buildings, filed its return of income for Assess...

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