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High Court

Bombay High Court Quashes Reassessment Notice for Co-operative Bank Due to Lack of Failure to Disclose Material Facts — Reassessment Initiated Beyond Four Years Invalid Under Section 147 Proviso. The Court held that the Revenue's reasons for reopening were based on a mere change of opinion on the same disclosed facts, failing to satisfy the jurisdictional precondition of failure to disclose fully and truly all material facts.

26 Aug 2024

The Petitioner, The Saraswat Co-operative Bank Ltd., filed a Writ Petition challenging a reassessment notice dated 30 March 2021 issued under Section ...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material. Notice Issued Beyond Four Years Based on Mere Change of Opinion on Already Scrutinized Transactions is Invalid.

7 Aug 2023

The petitioner, Sterlite Technologies Limited, challenged a notice dated 27 March 2021 issued under Section 148 of the Income Tax Act, 1961 for reasse...

High Court

Bombay High Court Allows Writ Petitions Challenging Income Tax Reassessment Notices for Lack of Proper Sanction. Reassessment notices under Section 148 of the Income Tax Act, 1961 quashed as the approval under Section 151 was granted without proper application of mind by the specified authority.

30 Sep 2025

The petitioner, Altisource Business Solutions India Pvt Ltd, filed three writ petitions challenging reassessment notices issued under Section 148 of t...

High Court

High Court of Bombay at Goa Quashes Reassessment Notice for Lack of Valid Reason to Believe in Income Tax Case. Failure to Disclose Material Facts Not Established as Petitioner Had Made Full Disclosure Under Income Disclosure Scheme, 2016.

11 Sep 2025

The petitioner, Prabhakar Nerulkar, an individual engaged in real estate business, filed a writ petition challenging a reassessment notice under Secti...

High Court

Bombay High Court Allows Petition Challenging Reassessment Notice Under Section 148 of Income Tax Act — Reassessment Based on Mere Change of Opinion Invalid as Full Disclosure Was Made During Original Assessment.

25 Mar 2015

The petitioner, Plus Paper Food Pac Ltd., filed a writ petition challenging a notice dated 18.11.2013 issued under Section 148 of the Income Tax Act, ...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Prior Recording of Reasons. Reopening under Section 148 of Income Tax Act, 1961 Held Invalid as Reasons Not Recorded Before Issuance of Notice.

20 Feb 2025

The petitioner, M/s. Indusind Media & Communications Ltd., filed its return of income for assessment year 2007-08, which was revised and subsequently ...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case for Lack of Failure to Disclose Material Facts — Reassessment Initiated Beyond Four Years Invalid Without Proof of Non-Disclosure Under Section 147 Proviso of Income Tax Act, 1961

27 Jun 2023

The petitioner, Hindoostan Mills Limited, filed a writ petition under Article 226 of the Constitution challenging a notice dated 30th March 2021 issue...

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 on Already Disclosed Loan Transactions is Invalid.

24 Aug 2021

The petitioner, Jainam Investments, a partnership firm engaged in trading of shares and securities, filed its income tax return for Assessment Year 20...

High Court

"High Court Invalidates Reassessment Notice Against Shri Saibaba Sansthan Trust Shirdi" "Reassessment quashed due to lack of new tangible material."

20 Dec 2024

The Bombay High Court held that reopening of assessments under Section 147 of the Income Tax Act, 1961, based on material already scrutinized during t...

Supreme Court

Supreme Court Upholds Income Tax Department's Reassessment in Escaped Assessment Case Due to Assessee's Failure to Disclose. Non-Disclosure of Firm Income and Unexplained Investments Attracted Section 34(1)(a) of Income-tax Act, 1922, Validating Reassessment for Assessment Year 1944-45.

21 Aug 1968

The appeals arose from reassessment proceedings under section 34 of the Indian Income-tax Act, 1922 concerning a Hindu Undivided Family for the assess...

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