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Reopening of Assessment Beyond Four Years Held Illegal Without Fresh Tangible Material. Reassessment Under Section 147 of Income Tax Act, 1961 Quashed Due to Lack of Jurisdiction and Change of Opinion

The Bombay High Court quashed the notice dated 27 March 2021 under Section 148 and the assessment order dated 29 March 2022, holding that: The reopen...

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Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Lack of Fresh Material. Reassessment Based on Mere Change of Opinion Without New Tangible Material is Invalid.

The petitioner, Zuari Foods and Farms Pvt. Ltd., filed its return of income for Assessment Year 2011-12 declaring nil income after claiming exemption ...

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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 Reassessment Notice for Stock Exchange in Income Tax Case — Reopening Beyond Four Years Invalid Without Failure to Disclose. Double Deduction Ground Already Decided in Assessee's Favour for Earlier Year.

The Bombay High Court allowed a writ petition filed by Bombay Stock Exchange Limited challenging a notice under Section 148 of the Income Tax Act, 196...

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Bombay High Court Quashes Reassessment Notice in Income Tax Case Due to Lack of Fresh Material and Change of Opinion. Reopening Beyond Four Years Invalid Without Allegation of Failure to Disclose Material Facts Under Section 147/148 of Income Tax Act, 1961.

The petitioner, an advocate by profession, challenged a notice dated 30 March 2011 issued under Section 148 of the Income Tax Act, 1961 seeking to reo...

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Bombay High Court Allows Writ Petition Quashing Reopening of Assessment Under Section 148 of Income Tax Act, 1961 for Assessment Year 2004-05. Mere Change of Opinion Cannot Justify Reopening When All Material Facts Were Disclosed During Original Assessment Under Section 143(3).

The petitioner, Shri Mahila Griha Udyog Lijjat Papad, a society registered under the Societies Registration Act, 1960 and the Bombay Public Trust Act,...

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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...

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Bombay High Court Allows Writ Petition Challenging Reassessment Notices for Non-Disclosure of Reasons. Failure to Supply Recorded Reasons Under Section 147 of Income Tax Act, 1961 Violates Natural Justice and Renders Reopening Invalid.

The petitioner, Ajay Oxycholoride Floorings, a partnership firm, challenged two notices dated 20th February 1990 and 3rd June 1991 issued by the Assis...