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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.

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

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Bombay High Court Quashes Reassessment Notice for Lack of Reasonable Belief of Income Escapement — Section 148 Income Tax Act, 1961. Reassessment Cannot Be Based on Mere Change of Opinion on Same Facts Already Considered During Original Assessment.

The petitioners, M/s. Devidayal Rolling Mills and its partner Sumanbala Aggarwal, challenged a notice dated 26th March 1992 issued under Section 148 o...

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Supreme Court Quashes High Court's Order in Tax Assessment Writ Petition Due to Statutory Remedy Foreclosure. High Court Exceeded Jurisdiction by Entertaining Writ Petition After Statutory Appeal Was Dismissed as Time-Barred Under Section 31 of the Andhra Pradesh Value Added Tax Act, 2005.

The dispute arose from a tax assessment order dated 21.6.2017 passed by the Assistant Commissioner of Commercial Taxes against the respondent, a regis...

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Bombay High Court Quashes Reassessment Notices for Lack of Reasonable Belief of Income Escapement — Section 148 Income Tax Act, 1961. Reopening of assessments based on mere change of opinion without tangible material is invalid.

The petitioner, Amar Hotchand Nagpal, a finance and estate broker, challenged three notices dated 23rd September 1997 issued under Section 148 of the ...

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High Court of Gujarat Quashes Reassessment Order Under Income Tax Act Due to Time-Barred Notice. Issuance of Order Beyond Surviving Time as Directed by Supreme Court Renders Proceeding Invalid.

The Special Civil Application under Article 226 of the Constitution was filed by the petitioner-company, Gayatri Microns Ltd., challenging the reasses...

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Bombay High Court Quashes Reopening of Assessment Under Section 147 of Income Tax Act, 1961 for Lack of Full and True Disclosure. Deduction Under Section 80M Allowed Based on Dividend Distributed Before Due Date.

The petitioner, Godrej Agrovet Limited, a domestic company, filed its return of income for Assessment Year 2003-04 on 27th November, 2003 declaring an...

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Bombay High Court Quashes Reopening of Assessment in Income Tax Case — No Failure to Disclose Material Facts. Reopening under Section 147 of Income Tax Act, 1961 Held Invalid as Assessee Had Made Full Disclosure in Return and Notes.

The petitioner, NYK Line (India) Ltd., a wholly owned subsidiary of a non-resident shipping line, filed its return of income for Assessment Year 2006-...