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Search Results for "reopening assessment"

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High Court

High Court Quashes Income Tax Reassessment Notice for Assessment Year 2015-16 as Time-Barred Under Amended Finance Act Provisions -- Petitioner Challenges Notice Under Section 148 of Income Tax Act, 1961 Based on Search Documents

20 Jan 2026

The High Court of Gujarat allowed a writ petition challenging a reassessment notice under Section 148 of the Income Tax Act, 1961 for Assessment Year ...

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

High Court of Karnataka Dismisses Revenue's Appeal in Transfer Pricing Adjustment Case — Held that ITAT Correctly Deleted Addition for Non-Compete Fee Paid to AE Without Adequate Justification. The court found no substantial question of law as the Tribunal's findings were factual and not perverse.

14 Aug 2015

The Revenue (Commissioner of Income Tax and Assistant Commissioner of Income Tax) filed appeals under Section 260A of the Income Tax Act, 1961 against...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Reason to Believe — Mere Change of Opinion Not Sufficient for Reassessment. The court held that the Assessing Officer had already applied his mind to the depreciation claim during original assessment and the subsequent reopening on the same issue without fresh tangible material was impermissible.

20 Oct 2011

The petitioner, Indo European Breweries Ltd., challenged a notice dated 17 March 2011 issued under Section 148(1) of the Income Tax Act, 1961 seeking ...

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 Same Facts Already Considered During Original Assessment Under Section 143(3) — Held That Change of Opinion Does Not Justify Reopening.

23 Sep 2011

The petitioner, Sanand Properties Pvt. Ltd., filed a writ petition under Article 226 of the Constitution challenging a notice dated 11 January 2011 is...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reopening Case — Reopening Invalid Due to Change of Opinion. Tribunal's finding that reassessment notice was based on mere change of opinion upheld under Section 147 of Income Tax Act, 1961.

5 Sep 2011

The case pertains to an appeal by the Revenue against the order of the Income Tax Appellate Tribunal (ITAT) which held that the reopening of assessmen...

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 Allows Writ Petition Challenging Reassessment Notices for Non-Disclosure of Reasons. Failure to Supply Recorded Reasons Under Section 147 of Income Tax Act, 1961 Violates Natural Justice and Renders Reopening Invalid.

16 Aug 2005

The petitioner, Ajay Oxycholoride Floorings, a partnership firm, challenged two notices dated 20th February 1990 and 3rd June 1991 issued by the Assis...

Supreme Court

Supreme Court Dismisses Income-Tax Officer's Appeal, Affirming That Notice Under Section 148 of Income-tax Act, 1961 Could Not Be Issued as Right to Reopen Under Section 34 of Income-tax Act, 1922 Was Barred. Section 297(2)(d)(ii) of 1961 Act Does Not Revive Time-Barred Reassessment Powers.

20 Aug 1968

The case involved an income-tax reassessment dispute arising under the Income-tax Act, 1922 and the Income-tax Act, 1961. The respondent, an assessee,...

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