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Search Results for "reopen assessment"

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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 for A.Y. 2012-13 Based on Search Action — Held That Section 153C Overrides Section 147 for Search-Related Assessments

18 Feb 2025

The Bombay High Court disposed of a batch of writ petitions challenging notices issued under Section 148 of the Income-tax Act, 1961 for the assessmen...

High Court

Bombay High Court Allows Writ Petitions Challenging Reopening of Assessments Under Section 147 of Income Tax Act, 1961 — Reopening Based on Change of Opinion and Non-Disclosure of Material Facts Held Invalid. The court held that reassessment notices issued without tangible material and based on a change of opinion are invalid, and that the assessee's failure to disclose primary facts is a prerequisite for invoking the proviso to Section 147.

19 Jan 2024

The judgment pertains to two writ petitions filed by corporate assessees challenging the reopening of their income tax assessments for the assessment ...

High Court

Bombay High Court Quashes Reassessment Notice in Income Tax Case for Lack of Fresh Material. Reopening of Assessment Under Section 147 of Income Tax Act, 1961 Invalid When Based on Same Material Already Considered in Original Assessment.

25 Aug 2023

The petitioner, Siemens Financial Services Pvt Ltd, a Non-Banking Finance Company registered with RBI, filed its return of income for Assessment Year ...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 148 of Income Tax Act for Lack of Fresh Material — Petitioner Had Disclosed All Facts in Original Assessment Under Section 143(3).

13 Mar 2023

The petitioner, Milton Plastics Limited, filed a writ petition under Article 226 of the Constitution of India challenging a notice dated 22.03.2004 is...

High Court

High Court of Karnataka Quashes Reassessment Notice for Lack of Jurisdiction — Dell India Pvt. Ltd. v. Joint Commissioner of Income Tax. Notice under Section 148 of Income Tax Act, 1961 issued without proper sanction and by officer lacking territorial jurisdiction over assessee.

23 Mar 2015

The petitioner, Dell India Pvt. Ltd., is a company engaged in the manufacture and sale of computer hardware and related products. For the Assessment Y...

High Court

High Court of Karnataka Quashes Reassessment Notice for Lack of Jurisdiction in Income Tax Case — Notice Issued Beyond Four-Year Limit Without Allegation of Failure to Disclose Material Facts. Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Assessment Year 2009-10 Quashed as Assessing Officer Failed to Record Satisfaction That Income Escaped Due to Assessee's Failure to Disclose Material Facts.

23 Mar 2015

The petitioner, Dell India Pvt. Ltd., is engaged in the manufacture and sale of computer hardware and related products. For the Assessment Year 2009-1...

High Court

Bombay High Court Quashes Reassessment Notices Under Section 148 of Income Tax Act for Lack of Fresh Material. Reassessment Based on Mere Change of Opinion Without New Tangible Material is Invalid.

8 May 2014

The petitioner, Debashu Services Private Limited, a private limited company registered under the Companies Act, 1956, is a regular assessee under the ...

High Court

Bombay High Court Quashes Reopening of Assessment in Income Tax Case — No Failure to Disclose Material Facts. Reassessment Notice Under Section 148 of Income Tax Act, 1961 Held Invalid as Original Assessment Was Based on Full Disclosure and Scrutiny.

17 Feb 2010

The petitioner, Multiscreen Media Private Limited, is engaged in the business of providing audiovisual television content, films, events, and related ...

Supreme Court

Supreme Court Dismisses Income-Tax Officer's Appeal, Affirming That Notice Under Section 148 of Income-tax Act, 1961 Could Not Be Issued as Right to Reopen Under Section 34 of Income-tax Act, 1922 Was Barred. Section 297(2)(d)(ii) of 1961 Act Does Not Revive Time-Barred Reassessment Powers.

20 Aug 1968

The case involved an income-tax reassessment dispute arising under the Income-tax Act, 1922 and the Income-tax Act, 1961. The respondent, an assessee,...

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