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High Court Quashes Reassessment Notice in Income Tax Case Due to Reopening on Same Adjudicated Material. Reassessment Under Section 148 of Income Tax Act, 1961 Held Impermissible When Based on WhatsApp Chat Evidence Already Considered in Prior Assessment and Appeal Proceedings.

The dispute arose from reassessment proceedings initiated by the Income Tax Department against an assessee for the Assessment Year 2019-20. The petiti...

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Bombay High Court Dismisses Revenue's Appeal in Income Tax Reassessment Case — Reopening Based on Change of Opinion Invalid. ITAT Correctly Held That Reassessment Under Section 147 Was Not Justified as There Was No Failure to Disclose Material Facts.

The case involves a tax appeal by the Commissioner of Income Tax against the order of the Income Tax Appellate Tribunal (ITAT) which upheld the cancel...

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Bombay High Court Quashes Reopening of Assessment in Income Tax Case — Change of Opinion Not Permissible Beyond Four Years. Reassessment Notice Under Section 148 of Income Tax Act, 1961 Set Aside as No Failure to Disclose Material Facts Was Alleged.

The petitioner, Shriram Foundry Ltd., challenged a notice dated 10 February 2011 issued under Section 148 of the Income Tax Act, 1961, seeking to reop...

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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.

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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Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Full Disclosure of Waiver of Interest in Original Assessment Precludes Reassessment After Four Years.

The Petitioner, Lok Housing and Construction Limited, challenged a notice dated 29 March 2011 issued under Section 148 of the Income Tax Act, 1961, se...

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Bombay High Court Allows Petition Challenging Reopening of Assessment in Income Tax Case Due to Lack of Fresh Material. Notice under Section 148 issued beyond four years quashed as there was no failure to disclose material facts and the reasons constituted a change of opinion.

The petitioner, Anil Radhakrishna Wani, a solicitor and advocate, was a partner of Little & Company and retired on 30 September 2002. Upon retirement,...

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Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material Beyond Four Years. Reopening of Assessment Under Section 148 of Income Tax Act, 1961 Held Invalid as There Was No Failure to Disclose Material Facts and No New Tangible Material.

The petitioner, Multiscreen Media Private Limited, a company engaged in providing audiovisual television software and related activities, filed return...

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Bombay High Court Quashes Reassessment Notice in Income Tax Case for Lack of Reasons. Notice Under Section 148 of Income Tax Act, 1961 Set Aside as Assessing Officer Failed to Record and Disclose Reasons for Reopening Assessment Completed Under Section 143(3).

The petitioner, Tanna Builders Pvt. Ltd., filed its return for assessment year 1985-86 on 28th June 1985. The Assessing Officer completed the assessme...