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Gujarat High Court Quashes Reassessment Notice in Income Tax Case Due to Non-Application of Mind by AO. Section 148 Notice for AY 2014-15 Set Aside as Reasons Recorded Were Mechanical and Lacked Independent Satisfaction.

The petitioner, Sanvira Holdings, a partnership firm part of the PSY Group engaged in real estate business, filed its return of income for Assessment ...

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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 Quashes Reassessment Proceedings Against Company Resolved Under IBC — Clean Slate Principle Applies to Past Tax Claims. Section 31 of IBC binds tax authorities, and no reassessment can be initiated for pre-resolution period.

The petitioners, Uttam Galva Metallics Ltd. (the corporate debtor) and its director, challenged reassessment proceedings initiated by the Income Tax D...

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Bombay High Court at Goa Quashes Reopening Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material and Change of Opinion. Assessment Reopening After Four Years Invalid Without Failure to Disclose True and Full Facts.

The petitioner, M/s. Anand Developers, a partnership firm, challenged a notice dated 29 March 2019 issued under Section 148 of the Income Tax Act, 196...

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Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material Beyond Four Years. Reopening Based on Change of Opinion Regarding Melting Loss Percentage Not Valid as Original Assessment Under Section 143(3) Had Examined the Issue.

The petitioner, Sound Casting Pvt. Ltd., challenged a notice under Section 148 of the Income Tax Act, 1961 seeking to reopen its assessment for Assess...

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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 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...