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Search Results for "Income Tax Reassessment"

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High Court

Gujarat High Court Quashes Income Tax Reassessment Notice Based on Cancelled GST Registration — Reliance on GST Proceedings Without Independent Verification Held Invalid. Reassessment proceedings under Section 148A of Income Tax Act, 1961 cannot be based solely on a GST registration cancellation order that has been set aside in appeal, as the foundation of the notice disappears.

23 Mar 2026

The petitioner, Piyush Mafatlal Shah, is engaged in the business of trading in gold, silver, diamond, and bullion under the proprietary concern M/s Pr...

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 Quashes Reassessment Notice Issued to Company That Ceased to Exist After Conversion into LLP — Notice Under Section 148 of Income Tax Act, 1961 Held Invalid as Issued to Non-Existent Entity. The court held that a notice under Section 148 issued to a company that had ceased to exist after conversion into an LLP is void ab initio and cannot be sustained.

3 Nov 2025

The petitioner, Erangal Comtrade and Consultancy LLP, challenged a notice dated 30 March 2021 issued under Section 148 of the Income Tax Act, 1961, se...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Being Time-Barred — Notice Issued Beyond Four-Year Limitation Period Without Proper Sanction. Reassessment Notice for AY 2019-2020 Issued on 12.04.2023 Held Without Jurisdiction as It Exceeded Limitation Under Section 149(1)(b) of Income Tax Act, 1961.

1 Aug 2023

The petitioner, Kartik Sureshchandra Gandhi, a businessman, filed a writ petition under Article 226 of the Constitution of India before the Bombay Hig...

High Court

Bombay High Court Quashes Section 179 Order Against Director for Company Tax Dues — Holds Revenue Failed to Prove Lack of Diligence or Recovery from Company. Petitioner not liable as director under Section 179 of Income Tax Act, 1961 for taxes of Kaizen Automation Pvt. Ltd. for AY 2008-09 and 2009-10 because Revenue did not establish that tax could not be recovered from the company despite reasonable efforts.

12 Jun 2023

The petitioner, Prakash B. Kamat, a mechanical engineer, developed a smart card-based ticketing solution and incorporated Kaizen Automation Pvt. Ltd. ...

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 Fresh Material. Assessment Reopened Beyond Four Years Based on Mere Change of Opinion Without New Tangible Material, Violating Section 147 Proviso.

17 Jan 2022

The petitioner, Macrotech Developers Limited (successor to Palava Dwellers Pvt. Ltd.), challenged a notice dated 27 March 2019 issued under Section 14...

High Court

High Court of Bombay at Goa Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Reopening Beyond Four Years Invalid as No Failure to Disclose Material Facts. The court held that the Assessing Officer cannot reopen assessment on the same material already examined during scrutiny, as it amounts to a change of opinion.

6 Mar 2018

The petitioner, Dempo Brothers Private Limited, a company incorporated under the Companies Act, filed its return of income for Assessment Year 2010-11...

High Court

Bombay High Court Quashes Reopening of Assessment Under Section 147 for Lack of Fresh Material — Reassessment Based on Same Facts as Original Assessment is Invalid. The Court held that the Assessing Officer cannot reopen an assessment on the same facts and material already considered during the original assessment under Section 143(3) of the Income Tax Act, 1961, as it amounts to a mere change of opinion.

10 Jun 2010

The Petitioner, Indian Oil Corporation Ltd., filed a writ petition challenging the reopening of its assessment for Assessment Year 2002-03 under Secti...

High Court

Bombay High Court Dismisses Revenue's Application for Reference in Co-operative Bank Deduction Case. Interest on Government Securities Earmarked Against Statutory Reserve Fund Held Eligible for Deduction Under Section 80P(2)(a)(i) of the Income Tax Act, 1961.

16 Aug 2005

The case involves an application under section 256(2) of the Income Tax Act, 1961, filed by the Commissioner of Income Tax, Mumbai City III, against t...

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