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Search Results for "reassessment proceedings"

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High Court

Gujarat High Court Quashes Reassessment Notice and Assessment Order in Income Tax Case Due to Lack of Incriminating Material and Non-Application of Mind. Section 153C Notice for Assessment Year 2010-11 Set Aside as No Satisfaction Recorded Regarding Incriminating Documents Found During Search of Third Parties.

30 Mar 2026

The petitioner, Pankajkumar Kanaiyalal Soni, an individual, challenged a notice dated 09.07.2021 issued under Section 153C of the Income Tax Act, 1961...

High Court

Gujarat High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Non-Consideration of Reply. Failure to Consider Petitioner's Detailed Reply in Section 148A(d) Proceedings Renders Order Invalid Due to Non-Application of Mind.

10 Mar 2026

The petitioner, Pierlite India Private Limited, a company incorporated under the Companies Act, 1956, engaged in manufacturing low voltage switchgear ...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reopening Case — Notice Based on Mere Change of Opinion Invalid. Reopening of assessment under Section 148 of the Income Tax Act, 1961 within four years held bad in law when based on change of opinion regarding deduction under Section 36(1)(viii).

9 Jul 2012

The appeal was filed by the Commissioner of Income Tax-3, Mumbai (revenue) under Section 260A of the Income Tax Act, 1961 against the order dated 27/8...

High Court

Bombay High Court Quashes Reassessment Notice Issued to Deceased Assessee Without Substituting Legal Heir — Notice Under Section 148A(b) and 148 of Income Tax Act, 1961 Held Invalid as Proceedings Not Initiated Against Proper Person

27 Jun 2023

The petitioner, Dhirendra Bhupendra Sanghvi, as the legal heir of Late Smt. Ushaben Bhupendra Sanghvi (the deceased assessee), filed a writ petition u...

High Court

Bombay High Court Quashes Reassessment Notice and Order in Income Tax Case Due to Lack of Full and True Disclosure Finding and Non-Disposal of Objections. Reopening Beyond Four Years Invalid as No Failure to Disclose Material Facts Alleged Under Section 147 First Proviso of Income Tax Act, 1961.

27 Feb 2025

The petitioner, Crystal Pride Developers, a partnership firm engaged in real estate development, filed its original return of income for Assessment Ye...

High Court

Bombay High Court Quashes Reassessment Notices Under Section 148 of Income Tax Act, 1961 for Lack of Reason to Believe — Amount Received on Retirement from Partnership Firm Held to be Capital Receipt Not Chargeable to Tax.

22 Feb 2010

The petitioners, Prashant S. Joshi and Dattaram Shridhar Bhosale, were partners in a real estate development partnership firm. They retired from the p...

High Court

Bombay High Court Allows Writ Petition Challenging Reopening of Assessment Under Section 148 of Income Tax Act, 1961 — No Fresh Tangible Material to Justify Reopening Beyond Four Years. The court held that the Assessing Officer must have reason to believe that income escaped assessment based on tangible material, and mere change of opinion does not justify reopening.

11 Mar 2024

The petitioner, BIC Cello (India) Private Limited, filed a writ petition challenging the reopening of its income tax assessment for Assessment Year 20...

High Court

Karnataka High Court Dismisses State's Revision Petitions in Agricultural Income Tax Reassessment Cases — Reassessment Notices Issued Beyond Limitation Period Invalid. The court held that reassessment proceedings under Section 35 of the Karnataka Agricultural Income Tax Act, 1957 must be initiated within the prescribed limitation period, and failure to do so renders the notice invalid.

25 Mar 2014

The case involves multiple civil revision petitions filed by the State of Karnataka against orders of the Karnataka Appellate Tribunal allowing appeal...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Independent Enquiry — Mere Borrowing of Reasons from Investigation Report Without Application of Mind Invalidates Reassessment. The Court held that the Assessing Officer must form his own 'reason to believe' and cannot mechanically adopt reasons from investigation reports without independent application of mind.

8 Mar 2023

The Petitioner, Digi1 Electronics Pvt. Ltd., is a company engaged in trading electronic appliances. It filed its return of income for Assessment Year ...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Full and True Disclosure — Investment in Bonds Prior to Sale of Property Does Not Disentitle Deduction Under Section 54EC. The Court held that the assessee had disclosed all material facts and the reopening was based on a change of opinion, thus invalid.

27 Jun 2012

The petitioner, Mrs. Parveen P. Bharucha, filed a writ petition under Article 226 of the Constitution of India challenging a notice dated 31.03.2011 i...

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