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High Court

High Court of Karnataka Dismisses Revenue's Appeal in Income Tax Reassessment Case — Notice Issued Beyond Four-Year Limit Invalid. Reassessment notice under Section 148 of the Income Tax Act, 1961, issued after expiry of four years from end of relevant assessment year, without alleging failure to disclose material facts, is barred by limitation under Section 149(1)(b).

10 Aug 2015

The case involves appeals filed by the Income Tax Department against an order of a learned Single Judge of the Karnataka High Court, which had quashed...

High Court

Gujarat High Court Quashes Reassessment Notice in Income Tax Case for Lack of Jurisdictional Fact — Reassessment Based on Change of Opinion Invalid Under Section 148 of Income Tax Act, 1961. Original Scrutiny Assessment Under Section 143(3) Had Already Examined Deduction Claim Under Section 35(2AB), No New Material Existed.

3 Feb 2026

The petitioner, Gujarat Metal Cast Industrial Private Limited, a company incorporated under the Companies Act, 1956 and engaged in manufacturing of Al...

High Court

Bombay High Court Dismisses Writ Petition Challenging Reassessment Notices Under Income Tax Act — Reassessment Valid as Income Escaped Assessment Due to Failure to Disclose Nature of Deposits. The court held that reassessment under Section 147 of the Income Tax Act, 1961 was justified as the petitioner failed to disclose that non-refundable deposits and funds were trading receipts, and the subsequent Supreme Court decision did not change the law but clarified it.

5 Jul 2005

The petitioner, Shri Chhatrapati Sahakari Sakhar Karkhana Ltd., a cooperative sugar factory, had its income tax assessments for the years 1972-73 to 1...

High Court

Gujarat High Court Quashes Reassessment Notice for AY 2015-2016 Due to Non-Compliance with Section 148A and Invalid Sanction. Reassessment proceedings set aside as notice issued after 01.04.2021 without following mandatory procedure under Section 148A(b) and sanction under Section 151 granted by incompetent authority.

3 Mar 2026

The petitioner, Narayan Industries, challenged a reassessment notice dated 09.06.2021 issued under Section 148 of the Income Tax Act, 1961 for Assessm...

High Court

High Court Quashes Income Tax Reassessment Notice Under Section 148 Due to Lack of Tangible Material. Reassessment Based on Seized Documents from Unrelated Entities Declared Invalid

13 Jan 2026

The High Court of Gujarat allowed the writ petitions challenging reassessment notices under Section 148 of Income Tax Act, 1961. The petitioner, an in...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Valid Sanction Under Section 151. Reassessment Notice Issued Beyond Three Years Held Invalid as No Approval from Specified Authority Was Obtained.

6 Feb 2024

The petitioner, Emkay Global Financial Services Limited, a company engaged in shares and stock broking, challenged a reassessment notice dated 31st Ma...

Supreme Court

Supreme Court Sets Aside High Court Order and Remands Case for Determination of Reassessment Conditions Under Income Tax Act. The Court Found That the High Court Had Not Examined Whether Income Escaped Assessment Due to Assessee's Failure to Disclose Fully and Truly All Material Facts as Required Under Section 34(1)(a) of the Income Tax Act, 1922.

10 Feb 1969

Background: The case arose from a challenge to reassessment notices issued under the Income Tax Act, 1961, by Modi Spinning & Weaving Mills Co. Ltd. a...

High Court

Bombay High Court Quashes Reassessment Notices for Non-Resident Taxpayer Due to Lack of Jurisdictional Satisfaction. Section 148 notices under Income Tax Act, 1961 set aside as Assessing Officer failed to record reasons and obtain sanction before issuing notices beyond four years.

7 Jul 2023

The petitioner, a non-resident Indian residing in Dubai, was regularly assessed to tax in India on income accruing or arising in India. He had investe...

High Court

High Court of Karnataka Dismisses Assessee's Appeal in Income Tax Reassessment Case — No Substantial Question of Law Arises. Reassessment Notice Under Section 148 of Income Tax Act, 1961 Upheld as Properly Issued Within Time and Based on Reasonable Belief of Income Escaping Assessment.

25 Jun 2018

The appellant, Gopal S. Pandit, proprietor of Pandit Developers, filed an appeal under Section 260-A of the Income Tax Act, 1961 against the order of ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Reasonable Belief and Change of Opinion. Reassessment Beyond Four Years Invalid Without Allegation of Failure to Disclose Material Facts.

7 Apr 2015

The petitioner, Nivi Trading Limited, a private limited company, filed its return of income for Assessment Year 2010-11 on 15th September 2010 declari...

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