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High Court

Karnataka High Court Allows Appeal in Income Tax Reassessment Case — Reassessment Invalid When Original Reasons Do Not Survive and Additions Made on New Grounds Without Proper Notice. The court held that under Section 147 of the Income Tax Act, 1961, the Assessing Officer cannot make additions on grounds different from those recorded in the Section 148 notice if the original reasons fail.

1 Jul 2015

The appellant, Sri N Govindaraju, an individual assessee with income from house property, transport business, capital gains, and other sources, filed ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Proper Sanction. Reassessment proceedings initiated without valid approval under Section 151 of the Income Tax Act, 1961 are invalid.

17 Oct 2025

The petitioner, Vilas Babankrao Kalokhe, challenged a reassessment notice dated 30-03-2022 issued under Section 148 of the Income Tax Act, 1961 for th...

High Court

Karnataka High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act Due to Lack of Tangible Material and Mere Change of Opinion. Reopening of Assessment After Full Disclosure and Acceptance of Logo Fee as Revenue Expenditure in Previous Years Held Impermissible.

10 Aug 2018

The writ petition was filed by the assessee, a limited company manufacturing kitchen appliances, challenging a notice dated 11.02.2014 issued under Se...

High Court

High Court Allows Appeal in Income Tax Reassessment Case Due to Lack of Fresh Material — Reopening Under Section 147/148 Invalid as No New Tangible Material Beyond Original Assessment. The court held that reopening based on survey conducted after original assessment under Section 143(1) without fresh material showing income escaping assessment is not permissible.

24 Aug 2015

The appellant-assessee, an individual, filed his return of income for the assessment year 2004-05 on 21.03.2005. The return was processed under Sectio...

High Court

High Court of Karnataka Quashes Reassessment Notice for Lack of Jurisdiction in Income Tax Case — Notice Issued Beyond Four-Year Limit Without Allegation of Failure to Disclose Material Facts. Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Assessment Year 2009-10 Quashed as Assessing Officer Failed to Record Satisfaction That Income Escaped Due to Assessee's Failure to Disclose Material Facts.

23 Mar 2015

The petitioner, Dell India Pvt. Ltd., is engaged in the manufacture and sale of computer hardware and related products. For the Assessment Year 2009-1...

High Court

Gujarat High Court Quashes Reassessment Order for Non-Compliance with Section 148A(b) Notice Requirements in Income Tax Case. Failure to Provide Relevant Material in Show Cause Notice Renders Reassessment Proceedings Invalid Under Section 147 of the Income Tax Act, 1961.

20 Jan 2026

The petitioner, Piyush Haridas Modi, an individual taxpayer, filed a writ petition under Articles 226 and 227 of the Constitution of India challenging...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reassessment Case — Reassessment Notice Issued Within Four Years Held Invalid Due to Full Disclosure. Tribunal's Finding of Full and True Disclosure by Assessee During Original Assessment Proceedings Upheld Under Section 148 of Income Tax Act, 1961.

8 Aug 2012

The appeal was filed by the Commissioner of Income Tax-3 (revenue) under Section 260A of the Income Tax Act, 1961 against the order dated 22/9/2009 of...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Reasonable Belief of Income Escaping Assessment. Share Premium Reassessment Based on Intrinsic Valuation Without New Material Held Invalid Under Section 147 of the Income Tax Act, 1961.

27 Jun 2023

The petitioner, SLS Energy Pvt. Ltd., challenged a notice dated 23 March 2015 issued under Section 148 of the Income Tax Act, 1961, for the assessment...

High Court

Bombay High Court Quashes Reassessment Notices Under Section 148 of Income-Tax Act, 1961 for Lack of Reasonable Belief of Income Escaping Assessment. Notices Issued Beyond Four Years Without Fresh Material Held Invalid.

6 May 2022

The petitioner, Sea Sagar Construction Co., a partnership firm, filed three writ petitions challenging notices dated 19 January 2012 issued under Sect...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Failure to Disclose Material Facts. Reassessment Beyond Four Years Invalid as Original Assessment Was Scrutiny Assessment and No Failure to Disclose Was Shown.

23 Aug 2024

The petitioner, an individual assessee, filed his income tax return for assessment year 2013-14 on 27 September 2013, declaring taxable income of Rs.7...

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