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Search Results for "queries during assessment"

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High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Reasons and Non-Application of Mind. The court held that the Assessing Officer failed to provide recorded reasons to the assessee and did not apply his mind to the fact that the transaction was already disclosed and examined during the original assessment under Section 143(3).

5 Sep 2023

The petitioner, Ashraf Chitalwala, an individual resident of India, filed his original return of income for Assessment Year 2015-16 on 27th September ...

High Court

Bombay High Court Quashes Reassessment Notice for Banking Company Due to Lack of New Material. Section 148 Notice Under Income Tax Act, 1961 Set Aside as Reasons for Reopening Were Based on Same Material Already Considered in Original Assessment.

1 Aug 2023

The petitioner, DCB Bank Ltd., challenged a notice dated 24 March 2021 issued under Section 148 of the Income Tax Act, 1961 for reopening the assessme...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case — Lack of Reasonable Belief of Income Escaping Assessment. Reopening Based on Change of Opinion Without Fresh Material Held Invalid Under Section 147 of the Income Tax Act, 1961.

5 Mar 2014

The petitioner, M/s. Bharat Bijlee Limited, challenged a notice dated 12.10.2012 issued under Section 148 of the Income Tax Act, 1961, and an order di...

High Court

High Court Quashes Income Tax Assessment Order for Non-Compliance with Time Limit and Violation of Natural Justice. Assessment Order Passed Beyond 12-Week Deadline Set by Court and with Insufficient Response Time to Show-Cause Notice Under Sections 143(3) and 144B of Income Tax Act, 1961 is Invalid.

20 Jan 2026

The dispute arose from an assessment order issued under the Income Tax Act, 1961 for the Assessment Year 2018-19. The petitioner, a manufacturer of ce...

High Court

Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Failure to Disclose Material Facts. Reassessment after four years barred unless Revenue shows assessee failed to fully and truly disclose all material facts.

27 Apr 2022

The petitioner, Bhavani Gems Private Limited, challenged a notice dated 30.03.2021 issued under section 148 of the Income Tax Act, 1961 for reopening ...

High Court

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

30 Jun 2023

The petitioner, Vedanta Limited (formerly Sterlite Opportunities and Ventures Limited), challenged a notice dated 28 March 2008 issued under Section 1...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reassessment Case Due to Change of Opinion. Queries During Original Assessment and Assessee's Response Amount to Formation of Opinion Barring Reopening Under Sections 143 and 147 of Income Tax Act, 1961, Lacking Tangible Material.

26 Oct 2021

By way of background, the appeal before the Bombay High Court arose under Section 268A of the Income Tax Act, 1961 against an order of the Income Tax ...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material. Reopening Under Section 148 of Income Tax Act, 1961 Based on Mere Change of Opinion on Provision for Unascertained Liabilities is Invalid.

26 Feb 2024

The petitioner, Bajaj Auto Limited, filed its return of income for Assessment Year 2016-17 on 29 November 2016, declaring total income of Rs. 4,860,25...

Supreme Court

Supreme Court Dismisses Revenue's Appeal Against Quashing of Reassessment Notice Under Income Tax Act Due to Lack of Tangible Material and Improper Reliance on Income Declaration Scheme. Reassessment Initiated Based on Accommodation Entries and Declaration Under Section 183 of Finance Act, 2016 Held Invalid as AO Failed to Establish 'Reasons to Believe' Income Escaped Assessment for AY 2010-11.

28 Mar 2022

The dispute arose from a reassessment notice issued by the Commissioner of Income Tax under Sections 147/148 of the Income Tax Act, 1961, for the asse...

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...

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