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Search Results for "reassessment proceedings"

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High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case for Lack of Reasonable Belief of Income Escapement. Notice under Section 148 of Income Tax Act, 1961 set aside as reasons recorded were based on mere change of opinion and not on fresh material.

9 Jan 2023

The petitioner, Asian Paints Ltd., a public limited company engaged in manufacturing and selling paints, challenged a notice dated 31st March 2021 iss...

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...

High Court

Bombay High Court Quashes Reassessment Notice and Order in Income Tax Case Due to Lack of Fresh Material and Change of Opinion. Guarantee Fee Reversal Issue Already Examined in Original Assessment and Pending Before Tribunal, Reassessment Barred by Third Proviso to Section 147 of Income-tax Act, 1961.

7 Mar 2025

The petitioner, Tata Communications Limited, filed its return of income for Assessment Year 2014-15 on 24 November 2014, which was revised twice in Ma...

High Court

High Court of Karnataka Quashes Reassessment Notice for Lack of Jurisdiction — Dell India Pvt. Ltd. v. Joint Commissioner of Income Tax. Notice under Section 148 of Income Tax Act, 1961 issued without proper sanction and by officer lacking territorial jurisdiction over assessee.

23 Mar 2015

The petitioner, Dell India Pvt. Ltd., is a company engaged in the manufacture and sale of computer hardware and related products. For the Assessment Y...

High Court

Bombay High Court at Goa Dismisses Tax Appeals in Reassessment Cases Under Section 147 of Income Tax Act, 1961. No Substantial Question of Law Found as Tribunal's Findings Were Based on Appreciation of Evidence.

30 Nov -0001

The judgment pertains to multiple tax appeals filed by individual assessees against the Commissioner of Income Tax, Goa. The appellants, including Sha...

High Court

Madras High Court Quashes Reassessment Notice Under Section 148 Income Tax Act as Time-Barred; Notice Dispatched on 1st April 2021 Beyond Limitation. Reopening Based on Accommodation Entry Information Without Independent Material Held Invalid for AY 2013-14.

20 Feb 2025

The petitioner, a proprietor of a petrol bunk, challenged a reassessment notice under Section 148 of the Income Tax Act, 1961 for Assessment Year 2013...

High Court

Bombay High Court Quashes Reassessment Notices Issued Beyond Time Limit Under Section 149 of Income Tax Act, 1961 — Notices Issued After Expiry of Six Years from End of Relevant Assessment Year Without Satisfying Conditions for Extended Period Held Invalid. The court held that the condition of income escaping assessment of Rs. 1 lakh or more for notice beyond six years was not satisfied, and the reasons recorded lacked tangible material.

8 Mar 2023

The judgment concerns five writ petitions filed by Jetair Pvt. Ltd. challenging notices dated 11 March 2021 issued under Section 148 of the Income Tax...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material — Notice Issued Beyond Four Years Without Allegation of Failure to Disclose Material Facts is Invalid Under Section 148 of the Income Tax Act, 1961.

4 May 2023

The petitioner, an individual assessee, filed her return of income for Assessment Year 2014-15 on 28 July 2014. The Assessing Officer completed the as...

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 Reassessment Order for Lack of Proper Opportunity of Hearing and Non-Communication of Section 151 Approval in Income Tax Reopening Proceedings. The court held that the Assessing Officer failed to grant a personal hearing as directed by the earlier order of the High Court and did not communicate the approval under Section 151 of the Income Tax Act, 1961, rendering the reassessment invalid.

20 Dec 2024

The petitioner, Wavy Construction LLP, challenged an order dated 14 October 2021 rejecting its objections against reopening of assessment under Sectio...

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