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Search Results for "reopen assessment"

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High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Non-Compliance with Procedural Requirements. Notice Issued Beyond Four-Year Limit Without Proper Sanction and Without Disclosing Reasons for Alleged Income Escaping Assessment.

16 Jun 2026

The petitioner, Chennai Container Terminal Pvt. Ltd., challenged a notice dated 26 March 2021 issued under Section 148 of the Income Tax Act, 1961 by ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148-A of Income Tax Act, 1961 — Internal Audit Objection Constitutes Change of Opinion. Notice Issued Beyond Three Years Based on Audit Objection Without Fresh Material Held Invalid as It Amounts to Mere Change of Opinion.

30 Jul 2024

The petitioner, Shri Dilip Laximan Powar, a paralyzed individual represented by his wife, runs a hardware and paint retail business as a proprietorshi...

High Court

Bombay High Court Quashes Reassessment Notice for Corporate Assessee in Income Tax Case — Notice Issued Beyond Limitation Period and Without Valid Information. Reassessment under Section 148 of Income Tax Act, 1961 invalid as notice under Section 148A(b) was issued beyond three-year limitation period and based on information already considered in original assessment.

28 Feb 2024

The petitioner, Godrej Industries Ltd., challenged a show cause notice dated 24th May 2022 issued under Section 148A(b) of the Income Tax Act, 1961, a...

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 Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Reassessment Based on Same Set of Facts as Original Assessment is Invalid. The court held that where the Assessing Officer had already considered the issue of deduction under section 80IA during the original assessment under section 143(3), reopening on the same ground without any new material amounts to a change of opinion and is not permissible.

27 Jun 2023

The petitioner, Nuclear Power Corporation of India Limited, a Government Corporation engaged in generation of electricity from atomic energy, filed it...

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 Reopening Notice Under Section 148 Income Tax Act for Lack of Fresh Material. Assessment Completed Under Section 143(3) Cannot Be Reopened Based on Same Material Already Considered.

8 Mar 2022

The petitioner, Regency Nirman Ltd., a company engaged in real estate development, filed its return of income for the assessment year 2013-14 on 29th ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Failure to Disclose Material Facts. Reassessment initiated beyond four years without establishing that assessee failed to fully and truly disclose all material facts is invalid.

3 Jan 2022

The petitioner, Vodafone Idea Ltd., successor in interest of M/s Idea Cellular Ltd., filed a writ petition challenging a notice dated 2nd August 2019 ...

High Court

High Court of Karnataka Dismisses Revenue's Appeal in Income Tax Reassessment Case — Tribunal's Order Restoring Assessment Set Aside. Reassessment Notice Under Section 148 Held Invalid as No Failure to Disclose Material Facts Was Established.

22 Jun 2015

The revenue appealed against the order of the Income Tax Appellate Tribunal, Bangalore Bench, which had set aside the reassessment order passed under ...

High Court

Bombay High Court Quashes Reopening Notice in Income Tax Case Due to Lack of Fresh Material. Loan Waiver Amount Already Disclosed During Original Assessment Cannot Be Reopened Under Section 147 of Income Tax Act, 1961 Without New Information.

22 Nov 2011

The Petitioner, Kimplas Trenton Fittings Ltd., filed a writ petition challenging a notice dated 25 March 2011 issued under Section 148 of the Income T...

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